Employee Code of Conduct - BNY Mellon … · · 2018-01-31Anti-corruption and improper payments // 28 ... Audit, Compliance, Human Resources and our Ethics Ofﬁce are readily available

CODE OF CONDUCT DOING WHATrsquoS RIGHT

rsquo

TABLE OF CONTENTS

CHAIRMANrsquoS LETTER 1

DOING WHATrsquoS RIGHT 2

HOW TO REPORT A CONCERN 3

KEY PRINCIPLES OF OUR CODE 4

WHAT YOU SHOULD KNOW ABOUT OUR

CODE OF CONDUCT 5-9

Our values 5

Purpose of our Code 6

Who must follow this Code 6

Waivers of the Code for executive officers 6

What is expected of employees 7

Cooperating with Regulatory Agencies 8

What is expected of managers 8

Managing risk as a manager 8

Responsibility to ask questions and report concerns 8

What happens when a concern is reported 9

Zero tolerance for retaliation 9

Cooperating with an investigation 9 Direct Communication with Government and Regulatory Authorities 10

Communication of Trade Secrets to Government and Regulatory Authorities 10

RESPECTING OTHERS 12-15

Mutual respect and professional treatment 12

Harassment-free environment 14

Safety and security 15

Managers responsibilities 15

AVOIDING CONFLICTS 16-25

Overview 16

Gifts and entertainment 17

Outside employment and business dealings 20

Outside service as a director officer general partner

political appointment or elected position 22

Ownership of an outside business 23

Fiduciary appointments 23

Personal investment decisions 23

Dealing with family and close personal friends 24

Corporate opportunities 25

CONDUCTING BUSINESS 26-29

Fair competition and anti-trust 26

Anti-corruption and improper payments 28

Combating financial crime and money laundering 29

WORKING WITH GOVERNMENTS 30-31

Your obligations 30

Basic principles 31

PROTECTING COMPANY ASSETS 32-38

Financial integrity 32

Additional standards for senior financial

professionals 33

Use of company assets 33

Protecting client and employee records and observing

our privacy principles 34

Records management 35

Use of computers systems and corporate

information 35

Inside or proprietary information 37

SUPPORTING OUR COMMUNITIES 39-41

Political activities 39

Investor and media relations 40

Charitable contributions and corporate sponsorship 41

Participating in trade associations conferences

and speaking engagements 41

ADDITIONAL HELP 42-43

The Code of Conduct does not alter the terms and conditions of your employment Rather it helps each of us to know what must be done to make sure we always Do Whatrsquos Right The most current version of the Code can be found on MySource

Throughout the Code references to company policies apply only to global policies that cover all employees and do not include additional policies you must follow that are specific to your location or line of business The Code is not intended to fully describe the requirements of referenced policies which can be found in their entirety on MySource

Charlie Scharf Chairman and Chief Executive Officer

Dear Colleagues

Our Code of Conduct guides our actions and decisions as individuals and as a company I expect each of us to personally commit to doing what is right regardless of the impact on a specific transaction or short-term working relationship

The Code provides guidance on six key areas of focus that relate to many of the situations you may encounter working at our company Respecting Others Avoiding Conflicts Conducting Business Working with Governments Protecting Company Assets and Supporting Our Communities

However the Code itself cannot address every possible situation We expect all employees to exercise good judgment using the Code as a primary resource to better understand our principles of ethical behavior and to seek help when unsure of the right course of action Above all each of us regardless of level are obligated to put the interests of our company clients and shareholders above any personal interest

As fundamental as the Code is it is not your only resource Your manager Legal Audit Compliance Human Resources and our Ethics Office are readily available resources if you are having difficulty understanding how our key principles apply to specific situations When in doubt I urge you to use these resources and escalate situations if you feel they are not getting the proper attention

Being a BNY Mellon employee means exercising good judgment and conducting yourself in a manner that is above reproach

1

DOING WHATrsquoS RIGHT

AT BNY MELLON ldquoDOING WHATrsquoS RIGHTrdquo MEANS ndash Contributing to an ethical culture is expected and valued ndash Conducting business in full compliance with all applicable laws and regulations

and in accordance with the highest ethical standards ndash Fostering honest fair and open communication ndash Demonstrating respect for our clients communities and one another ndash Being accountable for your own and team actions and ndash Being willing to take a stand to correct or prevent any improper activity or

business mistake

HOW TO DO WHATrsquoS RIGHT ndash Put company values policies and procedures into action ndash Know the laws and regulations affecting your job duties and follow them ndash Take responsibility for talking to someone if you see a problem and ndash Ask questions if you are unsure of the right thing to do

WHEN YOU ARE UNCERTAIN ASK YOURSELF THESE QUESTIONS ndash Could the action affect the companyrsquos reputation ndash Would it look bad if reported in the media ndash Am I uncomfortable taking part in this action or knowing about it ndash Is there any question of illegality ndash Will the action be questionable with the passage of time

If the answer to any of these questions is ldquoyesrdquo ask more questions Keep asking until you get a satisfactory answer Talk to your manager the Compliance and Ethics Department Legal or Human Resources or call the Ethics Office before doing anything further Donrsquot stop asking until you get the help you need

ITrsquoS YOUR OBLIGATION TO DO WHATrsquoS RIGHT

2

HOW TO REPORT A CONCERN

Usually the best place to start is by talking to your manager If this makes you uncomfortable then consider the options below

Ethics Help Line (operated by members of the companyrsquos Ethics Office) ndash United States and Canada 1-888-635-5662 ndash Europe 00-800-710-63562 ndash Brazil 0800-891-3813 ndash Australia 0011-800-710-63562 ndash Asia appropriate international access code

+800-710-63562 (except Japan) ndash Japan appropriate international access code

+800-710-6356 ndash All other locations call collect to 412-236-7519

Please note that your phone call can be anonymous

E-mail ethicsbnymelloncom (To remain anonymous please use the telephone help line for reporting your concern)

Ethics Hot Line (operated by EthicsPoint an independent hot line administrator) ndash United States and Canada 1- 866-294-4696 ndash Outside the United States dial the ATampT Direct

Access Number for your country and carrier then 866-294-4696

ATampT Direct Access Numbers by CountryCarrier ndash United Kingdom British Telecom 0-800-89-0011

CampW 0-500-89-0011 INTL 0-800-013-0011 ndash India 000-117 ndash Brazil 0-800-890-0288 ndash Ireland 1-800-550-000 Universal International

Freephone 00-800-222-55288 ndash Japan Softbank Telecom 00 663-5111 KDDI 00

539-111 ndash Australia Telstra 1-800-881-011 Optus

1-800-551-155 ndash Hong Kong Hong Kong Telephone 800-96-1111

New World Telephone 800-93-2266 ndash Singapore Sing Tel 800-011-1111 StarHub

800-001-0001

Web Report httpwwwethicspointcom (hosted on EthicsPointrsquos secure servers and is not part of the companyrsquos web site or intranet)

Please note that all contacts to EthicsPoint can be anonymous

Incident Reporting If your concern involves potential criminal or unusual client activity you must file an Incident Report within 72 hours In the US you can file an Incident Report using the icon on your PC desktop In other locations you should contact your compliance officer for assistance in following country-specific guidelines

Directorrsquos Mailbox If your concern involves questionable accounting or auditing matters you may also report your concern to the Presiding Director of the Board (who is independent of management) You can contact the Presiding Director by sending an e-mail to non-management directorbnymelloncom or by postal mail addressed to

BNY Mellon Corporation Church Street Station PO Box 2164 New York New York 10008-2164 USA Attention Non-Management Director

Please note the postal mail option can be anonymous

3

KEY PRINCIPLES OF OUR CODE

RESPECTING OTHERS We are committed to fostering an inclusive workplace where talented people want to stay and develop their careers Supporting a diverse engaged workforce allows us to be successful in building trust empowering teams serving our clients and outperforming our peers We give equal employment opportunity to all individuals in compliance with legal requirements and because itrsquos the right thing to do

AVOIDING CONFLICTS We make our business decisions free from conflicting outside influences Our business decisions are based on our duty to BNY Mellon and our clients and not driven by any personal interest or gain We are alert to any potential conflict of interest and ensure we identify and mitigate or eliminate any such conflict

CONDUCTING BUSINESS We secure business based on honest competition in the marketplace which contributes to the success of our company our clients and our shareholders We compete in full compliance with all applicable laws and regulations We support worldwide efforts to combat financial corruption and financial crime

WORKING WITH GOVERNMENTS We follow all requirements that apply to doing business with governments We recognize that practices that may be acceptable when dealing with a private company that is the client may cause problems or be a violation of law when working with a government

PROTECTING COMPANY ASSETS We ensure all entries made in the companyrsquos books and records are complete and accurate and comply with established accounting and record-keeping procedures We maintain confidentiality of all forms of data and information entrusted to us and prevent the misuse of information belonging to the company or any client

SUPPORTING OUR COMMUNITIES We take an active part in our communities around the world both as individuals and as a company Our long-term success is linked to the strength of the global economy and the strength of our industry We are honest fair and transparent in every way that we interact with our communities and the public at large

4

At the foundation of our Code of Conduct are our Values ndash Client Focus Integrity Teamwork and Excellence

Our values underscore our commitment to be a client-focused trusted financial institution driven by an empowered global team dedicated to outperforming in every market we serve

WHAT YOU SHOULD KNOW ABOUT OUR CODE OF CONDUCT

OUR VALUES Our values provide the framework for our decision-making and guide our business conduct Incorporating these values into our actions helps us to do what is right and protect the reputation of the company

ndash Client Focus Putting the client at the center of all that we do ndash Integrity Acting with the highest ethical standards for our company our

employees and our clients ndash Teamwork Fostering collaboration and diversity to empower employees to

build relationships and deliver insights ndash Excellence Setting the standard for leading-edge solutions innovation and

continuous improvement

WHAT OUR VALUES DO ndash Explain what we stand for and our shared culture ndash Span geographies and lines of business ndash Represent the promises made to our clients communities shareholders

and each other ndash Are critical to our success

5

PURPOSE OF OUR CODE Todayrsquos global marketplace is filled with a host of new challenges and changes but one constant guides us mdash the mandate to meet the highest standards of legal and ethical integrity

The Code of Conduct is the foundation of our commitment to Doing Whatrsquos Right but it is not intended to describe every law or policy that applies to you Nor does it address every business situation you may face Yoursquore expected to use common sense and good judgment and seek advice when yoursquore unsure of the proper response to a particular situation

The Code provides the framework and sets the expectations for business conduct It clarifies our responsibilities to each other clients suppliers government officials competitors and the communities we serve It outlines important legal and ethical issues Failing to meet these standards could expose our company to serious damage

WHO MUST FOLLOW THIS CODE All employees worldwide who work for BNY Mellon or an entity that is more than 50 percent owned by the company must adhere to the standards in our Code No employee is exempt from these requirements regardless of the position you hold the location of your job or the number of hours you work If you oversee vendors consultants or temporary workers you must supervise their work to ensure their actions are consistent with the key principles in this Code

WAIVERS OF THE CODE FOR EXECUTIVE OFFICERS Waivers of the Code are not permitted for any executive officer of BNY Mellon unless the waiver is made by the companyrsquos Board of Directors (or a committee of the Board) and disclosed promptly to shareholders Individuals who are deemed to be ldquoexecutive officersrdquo of BNY Mellon will be notified as appropriate

Compliance with the letter and the spirit of our Code of Conduct laws and regulations policies and procedures is not optional Itrsquos how we do business itrsquos the embodiment of Doing Whatrsquos Right

6

Q amp A

Q I work outside of the US Do US laws apply to me

A BNY Mellon does business all over the world which means that you may be subject to laws of countries other than the one in which you live You must follow those laws that apply to your business duties wherever you work BNY Mellon is the parent of our operating companies and is incorporated in the US so US laws may apply to certain business activities even if they are conducted outside of the US The reverse may also be true mdash other countries may apply their laws outside of their boundaries If you have questions about the laws that apply to your business activity ask your manager or contact the Legal representative who supports your line of business

WHAT IS EXPECTED OF EMPLOYEES Yoursquore responsible for contributing to our culture of Doing Whatrsquos Right by knowing the rules that apply to your job This includes company policies procedures laws and regulations governing the country and businesses in which you work Some lines of business may have more restrictive policies and procedures and certain countries may have laws that are unique to a location In these situations yoursquore expected to follow the more restrictive rules

Yoursquore expected to ask your manager if you have questions about performing your job If you do not get an adequate response itrsquos your duty to keep asking until you get a satisfactory answer You must question any request that does not comply with company policies laws or regulations or is inconsistent with our Code of Conduct

No manager or leader in our company can ask you to violate a law or regulation or to act in a manner inconsistent with our Code of Conduct You should challenge any such request and alert appropriate individuals

Identifying and managing risk is the responsibility of every employee Yoursquore required to adhere to the established internal controls in your area of responsibility and promptly elevate all risk compliance and regulatory concerns to your manager

Yoursquore expected to comply with applicable laws and regulations and follow this Code including the spirit of its intent The penalty for violating any provision may be disciplinary action up to and including dismissal If you violate a criminal law applicable to the companyrsquos business the matter will be reported to the appropriate authorities

You are required to use CODE RAP (Code Reports and Permissions) to report or obtain approval for certain activities that are noted throughout the Code of Conduct and various company policies (eg gifts entertainment and certain outside employment or positions) CODE RAP is a web-based system which you can learn more about by visiting MySource the companyrsquos intranet site If you need assistance or do not have access to a PC ask your manager for help

Yoursquore obligated to comply fully with our Code of Conduct and may be required to certify your compliance with the Code You will be notified of any required certifications

7

Q amp A

Q What is my role in managing risk

A Each employee plays an imporshytant role in managing risk when you ndash Perform your job with integrity

and in compliance with policies procedures and the law

ndash Adhere to the controls established for your business

ndash Ask questions if instructions are not clear or if you are unsure of the right thing to do

ndash Escalate issues immediately to your manager (eg an error a missed control wrongdoing or incorrect instructions)

Doing Whatrsquos Right means being accountable for your own and your teamrsquos actions and being willing to take a stand to correct or prevent any improper activity or a business mistake

COOPERATING WITH REGULATORY AGENCIES All employees are required to cooperate with regulators Your communications with regulatory personnel are expected to be responsive complete and transparent Any commitments you have made in response to exam findings and any responses to regulatory information requests are to be completed within the agreed time frame You must notify your manager immediately should situations arise that make it unlikely that you will meet the agreed upon commitments In addition your compliance officer should be advised of any delays in meeting regulatory commitments

WHAT IS EXPECTED OF MANAGERS Those who manage or supervise others have a special obligation to set an example in Doing Whatrsquos Right Some of the ways yoursquore expected to demonstrate this leadership include ndash Creating a culture of risk management compliance and ethics ndash Considering risk in all your decision making ndash Reinforcing with your staff the importance of early identification and

escalation of potential risks to the appropriate managers ndash Ensuring employees have the relevant resources to understand their job

duties ndash Monitoring compliance with the Code of Conduct company policies and

procedures of the employees you supervise ndash Fostering an environment in which employees are comfortable raising

questions and concerns without fear of retaliation ndash Reporting instances of non-compliance to the proper management level ndash Taking appropriate disciplinary action for compliance and ethics violations

and ndash Reviewing the Code of Conduct no less than annually with your staff

MANAGING RISK AS A MANAGER As a manager you must always consider risk in your decision making You are required to understand fully the risk compliance and regulatory issues that may impact the areas you serve You are required to escalate any concerns immediately to the appropriate management level to ensure the requisite attention is given to the matter In addition any corrective measures must be implemented timely thoroughly and in a sustainable manner

RESPONSIBILITY TO ASK QUESTIONS AND REPORT CONCERNS You are required to speak up immediately if you have a question or concern about what to do in a certain situation or if you believe someone is doing mdash or about to do mdash something that violates the law company policy or our Code of Conduct If you have a genuine concern you must raise it promptly

8

Q amp A

Q Where do I go for help if Irsquom uncomfortable talking to my management

A You can contact the Ethics Help Line or the Ethics Hot Line The contact information is located in the Code of Conduct on MySource and on the companyrsquos public Internet site

Q amp A

Q Can I report a concern anonymously

A Yes you can report your concern to the Ethics Help Line or Ethics Hot Line anonymously if you wish

If you have a question or concern your manager is usually a good place to start Other people you may go to for help or advice are ndash Your managerrsquos manager ndash Your line of business Compliance officer ndash Someone in the Human Resources or the Legal department

You must speak up If your concern is not addressed raise it through other channels You can always contact the Ethics Office through the Ethics Help Line or Ethics Hot Line

You can also visit the Doing Whatrsquos Right section of the Compliance and Ethics page on MySource for more information on reporting an issue or incident

WHAT HAPPENS WHEN A CONCERN IS REPORTED When you report a concern to the Ethics Help Line or Ethics Hot Line your concerns will be taken seriously and investigated fully Be prepared to give detailed information about your concern You can choose to be anonymous if you want Your confidentiality will be protected to the fullest extent possible and every effort will be made to quickly resolve your concern

These reporting mechanisms are meant to be used only when you have a genuine concern that something is wrong You will not be provided protection for your own misconduct just because you filed a report or if you knowingly give a false report

ZERO TOLERANCE FOR RETALIATION Anyone who reports a concern or reports misconduct in good faith and with the reasonable belief that the information is true is demonstrating a commitment to our values and following our Code of Conduct The company has zero tolerance for acts of retaliation Zero means zero No one has the authority to justify an act of retaliation Any employee who engages in retaliation will be subject to disciplinary action which may include dismissal

COOPERATING WITH AN INVESTIGATION Yoursquore required to cooperate with any investigation into alleged violations of our Code of Conduct laws regulations policies or procedures and are expected to be truthful and forthcoming during any investigation This includes situations where you are an involved party a witness or are asked to provide information as part of an investigation Any attempt to withhold information sabotage or otherwise interfere with an investigation may be subject to any level of disciplinary action up to and including dismissal

Remember investigations are confidential company matters To protect the integrity of the investigation you are not allowed to discuss any aspect of an investigation even the fact that an investigation is being conducted with other employees or the public

9

At the same time this requirement for confidentiality does not prohibit you from reporting legal violations to any governmental or regulatory body or official(s) or finance-related self-regulatory organization (collectively ldquoGovernmental Authoritiesrdquo) and you may do so either during or after your employment without notice to the Company Furthermore no BNY Mellon policy or agreement is meant to prohibit you from doing so or from participating in any benefits involved in such reporting The only restriction in this regard is that you are not authorized to disclose information covered by the Companyrsquos attorney-client privilege

DIRECT COMMUNICATION WITH GOVERNMENT AND REGULATORY AUTHORITIES The confidentiality of our information and the protection of that information is a theme that recurs several times in this Code and in many of our policies However nothing in this Code in those policies or in any agreement with BNY Mellon is meant to prohibit you from ndash initiating communications directly with cooperating with providing

relevant information to or otherwise assisting in an investigation by any Governmental Authorities regarding a possible violation of law

ndash testifying participating or otherwise assisting in an action or proceeding by a Governmental Authority relating to a possible violation of law or

ndash participating in any benefits for information provided to Government Authorities in the manner described in the first or second points above

You are permitted to report in this manner both during and after your employment here irrespective of any confidentiality agreements you may have signed or policies in place during your employment and without providing notice to the Company The only restriction is that you are not authorized to disclose information covered by the Companyrsquos attorney-client privilege

COMMUNICATION OF TRADE SECRETS TO GOVERNMENT AND REGULATORY AUTHORITIES While the Code prohibits you from revealing ldquotrade secretsrdquo outside of the Company you may do so without facing criminal or civil liability if ndash the material is revealed in confidence solely for the purpose of reporting

or investigating a suspected violation of law to a Federal State or local government official either directly or indirectly or to an attorney or

ndash the material is revealed in a complaint or other document filed under seal in a lawsuit or other proceeding Note that an individual who files a lawsuit for retaliation by an employer for reporting a suspected violation of law may disclose the trade secret to hisher attorney and may use the trade secret information in the court proceeding In such cases trade secret information must be filed under seal and it may be disclosed only under a court order

10


MUTUAL RESPECT AND PROFESSIONAL TREATMENT

HARASSMENT-FREE ENVIRONMENT

SAFETY AND SECURITY

MANAGERSrsquo RESPONSIBILITIES

KE

Y PR

INC

IPLE

RE

SP

EC

TING

OTH

ER

S

KEY PRINCIPLE RESPECTING OTHERS

MUTUAL RESPECT AND PROFESSIONAL TREATMENT One of our values is Teamwork and nothing damages a team more quickly than a lack of mutual respect For our company to be successful we all must work together toward common goals Employees and managers share a mutual responsibility to keep one another informed of any information that may be important to job performance and to understanding the organization Yoursquore expected to treat your fellow employees professionally mdash itrsquos what we owe each other in the workplace

The company recognizes your right to form personal relationships with those you meet in the workplace however yoursquore expected to use good judgment to ensure your personal relationships do not negatively affect your job performance or interfere with your ability to supervise others Favoritism open displays of affection and making business decisions based on emotions or personal relationships are inappropriate

Situations that involve borrowing money or making loans between employees or between one employee and a family member of another employee must be avoided unless it is of an incidental nature involving a minimal amount of money Managers should be particularly sensitive to situations involving lending money to those who report to them and avoid these workplace situations

(Reference Gifts Entertainment and Loans from One Employee to Another)

Q amp A

Q I asked a question in a staff meeting and the response I received was offensive mdash several people laughed at me and I was mortified What should I do

A The response you received was inappropriate Healthy communication can only occur in environments where different opinions can be exshypressed and respectful debate occurs Itrsquos okay to disagree with a colleague However it must be done in a professional and respectful way Talk to the person who made the remark If you feel uncomfortable doing so speak with your manager or Human Resources

12

Similarly gifts and entertainment between employees (including family members of another employee) can create conflicts Company policy places limits on the amounts that are permissible and amounts above those established limits require approval via CODE RAP


Managers must also be aware of situations where family members or close personal friends may also work at BNY Mellon The company prohibits any work situations where there is a direct reporting relationship between family members In addition wherever possible situations should be avoided that involve family members working in the same business unit at the same location or family members working in positions where they can jointly control or influence transactions Senior executives must be aware that there are restrictions on hiring family members If you encounter such a situation or are aware of one you should contact Human Resources for guidance

(Reference Hiring and Continued Employment of Employeesrsquo Relatives or Individuals Sharing Employeesrsquo Household)

KE

Y PR

INC

IPLE

RESPECTIN

G O

THER

S

13

HARASSMENT-FREE ENVIRONMENT BNY Mellon will not tolerate any form of harassment or discrimination Harassment can be verbal physical or include visual images where the effect creates an offensive atmosphere It can take many forms and includes jokes slurs and offensive remarks whether delivered verbally graphically or in electronic media including e-mail

Harassment also includes disrespectful behavior or remarks that involve a personrsquos race color sex age sexual orientation gender identity religion disability national origin or any other legally protected status Certain local laws or regulations may provide additional protection for employees so check with Human Resources or the Legal department in your local area if you have questions

Some countries have specific laws concerning sexual harassment that include ndash Intentional or unintentional unwelcome sexual advances with or

without touching

ndash Coerced sexual acts

ndash Requests or demands for sexual favors

ndash Other verbal or physical conduct of a sexual nature

Our commitment to a harassment-free environment applies in all work-related settings and activities whether on or off company premises and extends to employeesrsquo actions toward clients and vendors

Harassment of any kind will not be tolerated in the workplace

Q amp A

Q A colleague makes comments about my appearance that make me feel uncomfortable Irsquove told my colleague that I donrsquot like these comments but they continue and Irsquom told Irsquom too sensitive What am I supposed to do

A You should talk to your manager and ask for help If you do not feel comfortable talking to your manager talk to Human Resources or call the Ethics Help Line or Ethics Hot Line

14

SAFETY AND SECURITY BNY Mellon is committed to establishing and maintaining safe and healthy working conditions at all locations and to complying with laws that pertain to employee workplace safety Listed below are some of the principles of maintaining a safe and secure workplace

ndash You must contribute to maintaining a workplace free from aggression Threats intimidating behavior or any acts of violence will not be tolerated

ndash You may not use possess sell or transfer illegal drugs on company property In addition you wonrsquot be permitted to work if yoursquore using illegal drugs or impaired by alcohol

ndash You may not bring weapons onto company property This includes weapons used for sporting purposes or otherwise legal to possess Weapons of any kind have no place in the work environment

ndash You should be alert to individuals who are on company premises without proper authorization Make sure you observe all physical access rules in your location and report incidents of unauthorized entry to your manager or to security personnel

(Reference Company Identificashytion Card Issuance Display and Use of Company Identification)

Q amp A

Q I have reason to believe that a colleague is coming to the office intoxicated What should I do

A You should notify your manager immediately If yoursquore uncomfortable discussing this with your manager contact Human Resources


As part of a worldwide financial services organization managers have a special responsibility to demonstrate our values through their actions Managers must foster an environment of integrity honesty and respect This includes creating a work environment that is free from discrimination harassment intimidation or bullying of any kind This type of behavior will not be tolerated and is inconsistent with our values and the Code of Conduct

Managers also must ensure that all aspects of the employment relationship are free from bias and that decisions are based upon individual performance and merit

KE

Y PR

INC

IPLE

RESPECTIN

G O

THER

S

15



GIFTS AND ENTERTAINMENT

OUTSIDE EMPLOYMENT AND BUSINESS DEALINGS

OUTSIDE SERVICE AS A DIRECTOR OFFICER OR GENERAL PARTNER

OWNERSHIP OF AN OUTSIDE BUSINESS

FIDUCIARY APPOINTMENTS

PERSONAL INVESTMENT DECISIONS

DEALING WITH FAMILY AND CLOSE PERSONAL FRIENDS

CORPORATE OPPORTUNITIES

KE

Y PR

INC

IPLE

AV

OID

ING

CO

NF

LICTS

KEY PRINCIPLE AVOIDING CONFLICTS

OVERVIEW The way we conduct our daily business dealings with clients suppliers vendors and competitors determines our reputation in the marketplace far more than any other actions we take Each one of us contributes to BNY Mellonrsquos reputation Yoursquore expected always to act in a way that reflects our commitment to integrity and responsible business behavior

A conflict of interest is any situation where your interests and the companyrsquos interests or the interests of our clients appear to be in opposition When yoursquore in such a situation it may be difficult to objectively fulfill your job duties and your loyalty to the company or to our clients and may be compromised mdash or appear to be compromised Every business decision you make should be in the best interests of the company and our clients and not for your own personal gain or benefit So you may not engage in any activity that creates or even appears to create a conflict of interest between you and BNY Mellon or its clients You should not take any business action including any loan or guarantee for your personal benefit or to benefit a relative or close friend at the expense of the companyrsquos or a clientrsquos best interests

If you believe you have a conflict of interest or may be perceived to have such a conflict you must disclose this to your Compliance Officer or to the Ethics Office Yoursquore expected to cooperate fully with all efforts to resolve any such conflict The routine activities on the following pages can give rise to an actual or perceived conflict of interest

(Reference Business Conflicts of Interest)

Even if the conflict does not create an improper action the appearance of a conflict of interest can be equally damaging to our reputation

16

GIFTS AND ENTERTAINMENT Our clients suppliers and vendors are vital to BNY Mellonrsquos success Thatrsquos why itrsquos imperative that these relationships remain objective fair transparent and free from conflicts While business gifts and entertainshyment can be important to building goodwill they can also affect the relationship if your ability to exercise sound business judgment becomes blurred To prevent misunderstandings itrsquos recommended that at the beginning of the business relationship you discuss with your clients suppliers and vendors what is permissible under our Code

Fundamentally interactions with existing or prospective clients suppliers and vendors are business relationships that should be treated accordingly The inappropriate giving or receiving of gifts and entertainment can erode the distinction between a business and a personal relationship An appropriate benchmark is whether public disclosure of any gift or entertainment you accept or give would embarrass you or damage BNY Mellonrsquos reputation

If your judgment begins to be influenced inappropriately by a close relationship with a client supplier or vendor then you have crossed the line and you should remove yourself from that relationship

Q amp A

Q My line of business is considering asking a local vendor that we use from time to time to donate small gifts to a local charity Since wersquore not getting anything of value can we assume this is allowable

A No This is inappropriate Asking vendors or suppliers to donate gifts even if nominal in amount and for a charitable purpose gives the impression that they must honor our request to continue doing business with the company

The basic principle is that no gift or entertainment may be accepted or provided if it obligates you or appears to obligate you to the individual receiving or giving the gift or entertainment Gifts and entertainment should be defined in the broadest sense to include money securities business opportunities goods services discounts on goods or services entertainment corporate tickets company sponsored events food drink and any similar items

In addition to the rules noted on the next page that apply across the company certain lines of business may have more restrictive rules and requirements You are expected to know and follow the more rigorous standards that may apply to your job or your location

KE

Y PR

INC

IPLE

AVOID

ING

CO

NFLICTS

17

The following are NOT allowed regardless of the value

ndash Accepting or giving anything as a ldquoquid pro quordquo that is for doing something in return for the gift or entertainment

ndash Accepting or giving cash or cash equivalents (eg checks cash convertible gift certificates or cards securities and loans)

ndash Accepting or giving a gift or entertainment that violates any law or regulation or brings harm to BNY Mellonrsquos reputation

ndash Accepting or giving anything that could be viewed as a bribe payoff or improper influence

ndash Accepting or giving a gift or entertainment that violates any standard of conduct for your profession especially if you hold a license or a certification

ndash Using your position in any way to obtain anything of value from prospective or existing clients suppliers vendors or persons to whom you refer business

ndash Providing entertainment that is lavish or too frequent for an existing or prospective client vendor or supplier

ndash Participating in any entertainment that is inappropriate sexually oriented or inconsistent with ethical business practices

ndash Accepting gifts or entertainment from or giving them to any vendor or supplier during the selection or sourcing process whether or not you are the primary relationship manager or involved directly in the negotiation to secure the products or services

ndash Participating in any action that would cause the other person to violate their own companyrsquos standards for gifts and entertainment and

ndash Providing gifts or entertainment to an existing or prospective client supplier or vendor not recorded properly in the company books and records

Q amp A

Q I am vacationing in the Caribbean and my client has a home on the island that Irsquom visiting Shersquos been asking me to stay in her home Irsquoll make sure we discuss business and I may even be able to get some business referrals from her friends There wonrsquot be any expense to BNY Mellon Can I stay in the clientrsquos home

A No Staying in a clientrsquos home is inappropriate Your client is a business associate not a personal friend This type of entertainment could be viewed as improper and could bring harm to the companyrsquos reputation if disclosed to the public The fact that the company is not paying for any expenses is not relevant You should thank the client for the kind suggestion explain our policy and politely decline the offer

18

The following require express pre-approval or reporting via CODE RAP before you proceed Approval is required whether yoursquore the recipient of the gift or entertainment or yoursquore providing such to a client vendor or supplier

ndash Accepting a gift or bequest under a will or trust document of a client of BNY Mellon regardless of the amount

ndash Attending special high-profile events such as World Cup matches or Super Bowl games regardless of the stated amount on the tickets

ndash Giving or receiving any gift or entershytainment that exceeds amounts permissible in company policy (entertainment includes meals refreshments or other accommodashytions but should only be considered business entertainment if given in connection with a legitimate business meeting) and

ndash Giving gifts or entertainment to any US government employeeentity (US or non-US) ndash The laws surrounding gifts or

entertainment to government officials are complex so you should ask your manager for assistance or contact the Anti-Corruption and Government Contracting Unit of Compliance with questions

The following are usually acceptable but you should raise questions if yoursquore in doubt

ndash Gifts based upon obvious family or long-standing personal relationshyships (such as those between you and your parents children spouse or a childhood friend) where the circumstances make it clear that those relationships are the motivatshying factor for the gift rather than the business relationship

Q amp A

Q Irsquom worried about the impression my office is giving to the community We host what I consider to be lavish parties for prospective clients and some people seem to be constantly ldquoentertainingrdquo clients Should I be worried

A It depends It could be that your colleagues are engaging in legitimate business entertainment Itrsquos possible that the entertainment complies with the Code of Conduct and company policies and you may not have all the facts You should talk to your manager or the next level of management about your concern If yoursquore uncomfortable doing this or you get an unsatisfactory answer contact the Ethics Help Line or the Ethics Hot Line to report your concern

ndash Gifts of a nominal value (under $200 US or local equivalent) but only if the gift is given in connection with a commonly recognized event or occasion (eg holiday job event such as a promotion or retirement life event such as a wedding or a business event such as a conference sports or cultural event) Even in these situations you must report the gift or entertainment to your direct manager

ndash Promotional items of a nominal value such as pens calendars paperweights

ndash Items with little intrinsic value such as plaques certificates and trophies recognizing service and accomplishshyments for civic charitable educashytional or religious organizations

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19

ndash Discounts or rebates on merchandise or services that do not exceed those available to the general public or available to you as an employee of the company and

ndash Loans from other financial institutions so long as they are on customary terms for legally permissible purposes

If you receive a gift not in compliance with these requirements you must immediately return the gift to the sender If appropriate you should send a letter explaining the companyrsquos policy or your business linersquos policies

(Reference Gifts Entertainment and Other Expenses to Commercial Clients Suppliers or Vendors Policy and Anti-Corruption Policy)

OUTSIDE EMPLOYMENT AND BUSINESS DEALINGS Certain types of outside employment or business dealings may cause a conflict of interest or the appearance of a conflict Itrsquos your responsibility to recognize these situations Any activity that diminishes your ability to perform your job duties objectively benefits you at the expense of BNY Mellon competes with any business or service provided by the company or has the potential to damage our reputation will not be permitted

Certain types of outside employment or business dealings may not be accepted while employed by BNY Mellon including

ndash Employment or association with companies or organizations that prepare audit or certify statements or documents pertinent to the companyrsquos business

ndash Employment with clients competitors vendors or suppliers that you deal with in the normal course of your job duties and

ndash Any business relationship with a client prospect supplier vendor or agent of the company (other than normal consumer transactions conducted through ordinary retail sources)

Q amp A

Q A colleague of mine works part-time for a company that provides office supplies such as paper and pens to BNY Mellon Should I be concerned that his outside employment could be a conflict

A It does not seem likely this would be a conflict so long as your colleague is not involved in the decision making process to purchase supplies from the outside company or approve invoices or payments to the supplier If yoursquore concerned you may want to talk with your manager In addition you can always contact your Compliance Officer or the Ethics Office for guidance

20

Certain types of outside employment and business dealings require approval from the company before acceptance You must seek approval via CODE RAP Depending upon your job duties or other regulatory requirements your request may be denied or limits may be placed upon your activities The following positions require approval

ndash Employment involving the use of a professional license even if that license is not required for you to perform your current duties (eg FINRA real estate insurance certified accountant and attorney)

ndash Employment involving providing tax advice or tax return preparation

ndash Any type of employment in the financial services industry

ndash Employment that could compete with the company or divert business opportunities in any way

ndash Any position that is similar in nature to your present job duties and involves a ldquoknowledge transfer rdquo to the other organization

ndash Jobs that adversely affect the quality of your work distract your attention from your job duties or otherwise influence your judgment when acting on behalf of the company

ndash Employment of any kind that would negatively impact the companyrsquos financial or professional reputation and

ndash Serving as an expert witness industry arbitrator or other similar litigation support that is unrelated to BNY Mellon as these activities generally take a significant amount of time and have the potential to create conflicts of interest (eg taking a position that is contrary to company policies or procedures or otherwise conflicts with the interests of our clients)

Even if your outside employment is approved or permissible under the Code you may not solicit employees clients vendors or suppliers nor may you utilize the companyrsquos name time property supplies or equipment All approvals granted for outside employshyment expire after one year Annual re-approval via CODE RAP is required since facts and circumstances may change

(Reference Outside Affiliations Outside Employment and Certain Outside Compensation)

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21

OUTSIDE SERVICE AS A DIRECTOR OFFICER GENERAL PARTNER POLITICAL APPOINTMENT OR ELECTED POSITION You must obtain prior approval before you serve as a board member officer or general partner of the following

ndash All for-profit companies and

ndash Non-profit entities where any of the following circumstances exist ndash There is a client business or financial relationship between the entity and

BNY Mellon including receiving charitable contributions grants or foundation money

ndash The entity is a trade or industry organization (eg Financial Industry Regulatory Authority or the Chartered Financial Analyst Institute)

ndash You receive any type of compensation (eg cash securities goods services) ndash You have been asked by BNY Mellon to serve the organization ndash The entity is any type of government agency or your position is considered to

be a public official (whether elected or appointed)

You may not serve until you have full approval from BNY Mellon as required by policy and documented in CODE RAP If you are compensated you may be required to surrender the compensation if there is a potential conflict of interest or yoursquore serving the outside entity on behalf of BNY Mellon Annual re-approval via CODE RAP is required as facts and circumstances may change so you may not be given permission to serve every year

Even if the service does not require approval you must notify BNY Mellon of any anticipated negative publicity and you must follow these guidelines while you serve

ndash Never attempt to influence or take part in votes or decisions that may lead to the use of a BNY Mellon product service or other type of benefit to the company the entity records must reflect that you abstained from such a vote or discussion

ndash You must ensure the entity conducts its affairs lawfully ethically and in accordance with prudent management and financial practices If you cannot then you must resign

(Reference Accepting Compensation When Serving as a Board Member or Senior Officer of an Outside Entity)

Q amp A

Q Irsquove been asked to sit on the board of a local non-profit group They use our Wealth Management group to manage their charitable giving program I donrsquot have any business dealings with the non-profit group and donrsquot work in Wealth Management Do I have to report this

A Yes The non-profit entity is a client of BNY Mellon It does not matter which line of business has the client relationship or whether or not you have any business dealings with the group You must submit a CODE RAP form and receive approval before you agree to serve

22

OWNERSHIP OF AN OUTSIDE BUSINESS If you own a business (either as a sole proprietor or partial owner) you must seek approval for this ownership via CODE RAP Yoursquoll be required to provide pertinent details such as any relationship with BNY Mellon (includshying employees) any compensation payment received time required and potential conflicts of interest (actual or in appearance) Annual re-approval via CODE RAP is required as facts and circumstances may change


FIDUCIARY APPOINTMENTS Fiduciary appointments are those where you act as a trustee executor administrator guardian assignee receiver custodian under a uniform gifts to minors act investment adviser or any capacity in which you possess investment discretion on behalf of another or any other similar capacity In general yoursquore strongly discourshyaged from serving as a fiduciary unless yoursquore doing so for a family member All requests to serve as a fiduciary with the exception of serving for a family member who is not a BNY Mellon client require approval through CODE RAP

If there is a client relationship there may be restrictions or controls placed on your service or you may be denied the ability to serve in such a fiduciary capacity

In all situations where yoursquore acting as a fiduciary you must follow these guidelines

ndash Do not represent that yoursquore performing the same professional services that are performed by a bank or that you have access to such services

ndash Do not accept a fee for acting as a co-fiduciary with a bank unless you receive approval from the board of directors of that bank and

ndash Do not permit your appointment to interfere with the time and attention you devote to your BNY Mellon job duties

PERSONAL INVESTMENT DECISIONS Your personal investments and those of certain family members could lead to conflicts of interest Therefore yoursquore required to comply with the companyrsquos Personal Securities Trading Policy including adhering to the restrictions placed on trading in BNY Mellon securities and a strict prohibition against insider trading Certain employees will have additional restrictions placed on their personal investments that may include reportshying and pre-clearing various types of securities transactions You must be familiar with the responsibilities that apply to your job and yoursquoll be expected to follow those rules

In addition if you have (or anyone who reports to you has) responsibility for a client supplier or vendor relationship as part of your job duties you must be cautious about potential investments in that business or its securities particularly for privately held or thinly traded public companies and ensure your full compliance with the Personal Securities Trading Policy

(Reference Personal Securities Trading Policy)

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23

DEALINGS WITH FAMILY AND CLOSE PERSONAL FRIENDS You should be particularly sensitive to business situations involving family members household members or close personal friends In general a family member or close personal friend should not have any business dealings with you or with anyone who reports to you This also includes situations where your family members or close personal friends provide an indirect service to a client for whom you have responsibility

You must disclose any such situation to your manager and your Compliance Officer and cooperate with all efforts to resolve such conflicts


Q amp A

Q A client of mine is considering hiring my wife as his accountant I did not make the referral to my client Is this okay

A This situation could cause a conflict of interest and you should contact your manager and your Compliance Officer immediately If your wife is acting as your clientrsquos accountant she may be relying upon information BNY Mellon provides on the clientrsquos account This is a situation that puts you in a potential conflict of interest so you may be required to resign from the clientrsquos account if he hires your wife

Q My son works for a consulting company that BNY Mellon routinely hires for software development My job does not require that I interact with him and I have no influence or input over the decision to hire the consulting company Is this okay

A It doesnrsquot appear that there are any conflicts of interest with your son working for the consulting company and your job at BNY Mellon To be certain discuss this matter with your manager or your Compliance Officer so that you can be sure there are no conflicts with this situation

24

CORPORATE OPPORTUNITIES You owe a duty to BNY Mellon to advance its legitimate business interests when the opportunity arises You and your family members are prohibited from personally benefiting from opportunities discovered through the use of company property or information that you directly or indirectly obtained through your position at BNY Mellon

Your actions must not compete in any way with businesses the company engages in and you may neither ask for nor accept a business opportunity that may belong to BNY Mellon or could appear to belong to it

You may not give legal tax or other professional advice to clients prospects vendors or suppliers of the company You may not give investment advice to clients prospects vendors or suppliers of the company unless this activity is part of your regular job responsibilities You must also be cautious if clients prospects suppliers or other employees seek your guidance or your recommendation of a third party professional who provides these services such as an attorney accountant insurance broker stock broker or real estate agent

If you make such a recommendation you must follow these requirements

ndash Provide several candidates and ensure you show no favoritism toward any of them

ndash Disclose in writing that the recommendations are in no way sponsored or endorsed by the company

ndash Do not accept any fee (now or in the future) nor may you expect any direct or indirect benefit (eg more business from a better relationship) from the recommendation

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All transactions with your clients suppliers or vendors must be handled strictly on an ldquoarmrsquos-length basisrdquo meaning that the terms of all transactions must not even suggest the appearance of a personal advantage

25




FAIR COMPETITION AND ANTI-TRUST

ANTI-CORRUPTION AND IMPROPER PAYMENTS

COMBATING FINANCIAL CRIME AND MONEY LAUNDERING

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KEY PRINCIPLE CONDUCTING BUSINESS

FAIR COMPETITION AND ANTI-TRUST BNY Mellon is committed to fair dealing with our clients suppliers competitors and employees The company is also committed to open competition as we believe this benefits our clients the company and the community at large We compete vigorously but only in full compliance with the laws and regulations of the numerous jurisdicshytions in which we do business and in the spirit of honesty and integrity

All BNY Mellon entities must comply with the various ldquofair competitionrdquo and ldquofair dealingrdquo laws that exist in many countries and ldquoanti-trustrdquo laws in the US The general purpose of these laws is to protect the markets from anti-competitive activities Some examples of such anti-competitive activities are those that involve entering into formal or informal agreements whether written or oral with competitors regarding

ndash Fixing prices or terms or any information that impacts prices or terms

ndash Allocating markets sales territories or clients including sharing marketing plans or strategic documents

ndash Boycotting or refusing to deal with certain suppliers vendors or clients (unless required by a law or governing body such as the Office of Foreign Assets Control) and

ndash Making the use of a product or service from a supplier or vendor conditional upon their use of our services or products

The principles of fair dealing require us to deal fairly with our clients suppliers competitors and employees Unfair advantage may not be taken through

ndash Manipulation

ndash Concealment

ndash Abuse of privileged information

ndash Misrepresentation of material facts or

ndash Any other unfair-dealing practices

Q amp A

Q A close friend works for a competitor of BNY Mellon We sometimes talk about the challenges we have in marketing certain products and bounce ideas off one another Is this a problem

A Yes Yoursquore discussing confidential information that belongs to the company You may also be violating anti-trust or anti-competitive laws Do not talk about these types of matters with your friend family members or anyone outside of the company

26

The competition and anti-trust laws are many and complex so if you have any question as to whether a particular activity is legal or in compliance with the spirit of these laws you should contact a member of the Legal departshyment The following points reinforce the significance and complexity of these laws

ndash The laws can vary within the same country or organization For example several states within the US have fair competition laws in addition to the federal anti-trust laws Likewise within the EU individual countries may have laws that apply in addition to EU laws

ndash The laws of certain countries may apply to conduct that takes place outside of that country (eg the US and EU)

ndash Violations of these laws typically carry harsh penalties Most permit significant monetary penalties for both the company and the individual employee and some permit convicted individuals to be imprisoned

ndash Meetings at professional gatherings trade associations or conferences are particularly vulnerable to potential violations If yoursquore involved in any discussion with a competitor that begins to suggest anti-competishytive or anti-trust activity or gives the appearance of this kind of activity you must inform the competitor that the discussion must cease If it does not you must remove yourself from the group Immediately report the incident to the Legal department to protect both you and the company and

ndash Many countriesrsquo competition laws have provisions that make it illegal to monopolize or to abuse a dominant position in a market You should check with the Legal department if yoursquore a senior manager of a business and have concern about these issues

Complying with fair competition and anti-trust laws also means that you may not use information or materials that belong to our competitors This includes using information that a former employee of a competitor may bring with them to BNY Mellon We succeed in the marketplace based on our own merits and do not engage in corporate ldquoespionagerdquo or unethical means to gain advantage on the competition Yoursquore expected to comply fully with the letter and the spirit of all fair competition and anti-trust laws

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27

ANTI-CORRUPTION AND IMPROPER PAYMENTS Most countries in which we do business have laws that prohibit bribes to governments their officials and commercial (non-government) clients The term ldquoofficialsrdquo can be applied broadly to include officials of political parties political candidates employees of governments and employees of government-owned businesses BNY Mellon employees are subject to the Foreign Corrupt Practices Act and the UK Bribery Act You must comply with these laws regardless of the line of business in which you work or your country of residence

Any attempt to pay or offer money or anything of value to influence the actions or decisions of such officials may result in a violation of the above-referenced laws Violation of these laws is a serious offense which can lead to significant penalties for the company and for you individually Yoursquore required to comply fully with the Companyrsquos Anti-Corruption Policy and adhere to all associated rules including the following

bull Do not offer or give anything of value (including gifts meals entertainment or other benefits) to a US or non-US ldquoofficialrdquo to obtain or retain business or secure any improper advantage

Note in particular that ldquothings of valuerdquo may include jobs or internships or offers thereof Company Policies require that any and all candidates for employment (whether permanent limited duration or as an intern) proceed through the formal HR recruiting process You must not engage in informal recruiting hiring or hiring discussions outside of the formal HR recruiting process In addition ldquothings of valuerdquo may also include consulting contractor or temporary work assignments at BNY Mellon whether or not a third party employment staffing agency is involved You must adhere to all internal controls applicable to such arrangements

bull Do not agree to hire or exert any influence in the hiring of any client or potential client or any relative or other person in whom the client or potential client may be interested

bull Do not accept or present anything if it obligates you or appears to obligate you and ensure that all hospitality entertainment and gifts are in accordance with applicable corporate policies and preceded by all required internal approvals

bull Do not attempt to avoid laws by making payments through third parties be cautious when selecting or dealing with agents or other third-party providers

bull Never make any payment that you do not record on company books and records or make misleading accounting entries

bull Seek guidance when circumstances are unclear or yoursquore asked to make or approve a payment or take any other action that makes you uncomfortable and

bull Report any observations of others engaging in any behavior that you believe is improper

(Reference Anti-Corruption Policy)

28


Money laundering is the process by which individuals or entities attempt to conceal unlawful funds or othershywise make the source of the funds appear legitimate As a member of the financial services community you have a special obligation to support law enforcement throughout the world to combat various types of financial crime such as attempts to launder money for criminal activity and finance terrorist operations Yoursquore expected to comply fully with all anti-money laundering laws and only conduct business with reputable clients involved in legitimate business activities that use funds derived from lawful purposes

It is critical to the health of the company that every employee adheres to the companyrsquos strict ldquoknow-your-customerrdquo policies In addition to our global policies individual lines of business have detailed policies and procedures that address unique requirements and circumstances Yoursquore expected to know those procedures and follow them Ask your manager for guidance Knowing your customer means following established customer identification protocols for your business line validating that the individual or entity and the source of their funds is legitimate

Failing to detect suspicious transactions or doing business with any person or entity involved in criminal or terrorist activities puts

Q amp A

Q A longtime client started a new company that purchases medical equipment for a facility in the Middle East The payments are made via wire transfers from an account of another company she owns in the Cayman Islands The bank account of the Cayman Island company is located in a European country Should I be concerned

A Yes Transferring funds to or from countries unrelated to the transaction or transfers that are complex or illogical is a significant red flag Yoursquore obligated to file an Incident Report no later than 72 hours from the time you identify the activity as suspicious

the company and you at serious risk Acshycordingly the company will not tolerate any circumstance where an individual or business unit circumvents anti-money laundering policies or procedures or fails to report suspicious activity No amount of revenue and no client relationship are worth the risk of doing business with those involved in criminal or terrorist activity If you suspect or detect any suspicious activity you must file an Incident Report as soon as possible and no later than 72 hours after detection No manager or executive has the authority to suppress such reports

(References Global Anti-Money LaunderingKnow-Your-Custo mer PolicyTax Evasion Prevention Policy Anti-Money Laundering Training Policy Policy on Identifying Investigating and Reporting Fraud Money Laundering etc)

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29




YOUR OBLIGATIONS

BASIC PRINCIPLES

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GO

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NTS

KEY PRINCIPLE WORKING WITH GOVERNMENTS

YOUR OBLIGATIONS BNY Mellon conducts business with national and local governments and with government-owned entities While you must always follow the standard of Doing Whatrsquos Right with any client you should be aware that there are special rules when doing business with a government Some practices that are acceptable when a private company is your client such as nominal gifts or entertainment may cause problems or in some cases be a violation of law when working with governments

If yoursquore involved in any part of the process of providing services to a government entity you have a special obligation to follow the basic principles in this section of the Code These principles also apply in circumstances where you may be supervising the work of third parties in support of a government client (eg consultants contractors temporary workers or suppliers)

If yoursquore a manager or recruiter who has responsibility for hiring decisions you may have additional unique requirements For example certain jurisdictions such as the US have laws concerning employment discussions and the hiring of former government officials and their family members or lobbyists Check with your local Human Resources representative or the Legal department in such circumstances to be sure yoursquore following requirements of the law

Q amp A

Q I have clients in a country where some businesses have been ldquonationalizedrdquo and are now owned and run by the state Are the people I deal with in these circumstances considered to be officials of the government

A You should assume the answer is yes The laws can be complicated so contact the Legal department for guidance

Q Irsquom hosting a dinner for a few of the larger clients in my region One of the clients I was going to invite is the representative for the account we manage for the State of New Jersey Do I have to notify anyone

A Yes You may not proceed until yoursquove received approval via CODE RAP from the Anti-Corruption and Government Contracting Unit of Compliance

30

BASIC PRINCIPLES ndash Know the restrictions or limitations on

presenting and receiving hospitality ndash Do not offer or accept gifts to or from

representatives of governments that do not comply with company policies

ndash Never accept or offer anything of value meant to induce or influence government employees or officials as this gives the appearance of a bribe and

ndash Donrsquot ldquotiprdquo government officials or offer ldquoinducementrdquo payments

ndash Do not accept or present anything if it obligates you or appears to obligate you

ndash Observe a ldquohigher standard of carerdquo ndash Never destroy or steal government

property ndash Donrsquot make false or fictitious statements

or represent that agreements have been met if they havenrsquot

ndash Donrsquot deviate from contract requirements without prior approval from the government and

ndash Never issue invoices or charges that are inaccurate incorrect or unauthorized

ndash Cooperate with government investigations and audits ndash Donrsquot avoid contravene or otherwise

interfere with any government investigation or audit and

ndash Donrsquot destroy or alter any company documents (whether electronic or paper) in anticipation of a request for those documents from the government

Itrsquos important to note that in addition to the basic principles above if your client is a US federal state or local government there are very specific legal requirements and company policies that you must follow These obligations apply to all businesses that deal with US federal state or local entities or officials regardless of the location or the line of business providing the service even in locations outside the US

(References Doing Business with the Government Government Contracts Gifts Entertainment and Payments to Governments)

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31




FINANCIAL INTEGRITY

ADDITIONAL STANDARDS FOR SENIOR FINANCIAL PROFESSIONALS

USE OF COMPANY ASSETS

PROTECTING CLIENT AND EMPLOYEE RECORDS AND OBSERVING OUR

PRIVACY PRINCIPLES

RECORDS MANAGEMENT

USE OF COMPUTERS SYSTEMS AND CORPORATE INFORMATION

INSIDE OR PROPRIETARY INFORMATION

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ETS

KEY PRINCIPLE PROTECTING COMPANY ASSETS

FINANCIAL INTEGRITY BNY Mellon is committed to keeping honest accurate and transparent books and records Yoursquore expected to follow established accounting and recordkeeping rules and to meashysure and report financial performance honestly Investors count on us to provide accurate information so they can make decisions about our company All business records must be clear truthful and accurate and follow generally accepted accounting principles and laws

You may not have any secret agreement or side arrangements with anyone mdash a client another employee or their family member or a supplier vendor or agent of the company

The financial condition of the company reflects records and accounting entries supported by virtually every employee Business books and records also include documents many employees create such as expense diaries and time sheets

Falsifying any document can impact the financial condition of the company As a public company BNY Mellon is required to file reports with government agencies and make certain public statements Many people and entities use these statements including

ndash Accountants mdash to calculate taxes and other government fees ndash Investors mdash to make decisions about buying or selling our securities and ndash Regulatory agencies mdash to monitor and enforce our compliance with government

regulations

Yoursquore expected to maintain accurate and complete records at all times Financial integrity is fundamental to our success and falsification or misrepresentation of any company books records or reports will not be tolerated

Q amp A

Q I think a co-worker is submitting reports that indicate she worked overtime that she did not actually work I donrsquot want to get anyone in trouble so what should I do

A Reporting hours not worked is a form of theft This is a serious issue and may be a violation of law You must report your concern to your manager or Human Resources If yoursquore uncomfortable raising this issue with your manager file an Incident Report or contact the Ethics Help Line or the Ethics Hot Line to report your concern

32

ADDITIONAL STANDARDS FOR SENIOR FINANCIAL PROFESSIONALS If yoursquore responsible for the accuracy of the companyrsquos financial filings with regulators you have a higher duty to ensure your behavior folshylows the most stringent standards of personal and professional conduct This includes the Chief Exshyecutive Officer President Chief Financial Officer Company Controller and such other individuals as determined by the General Counsel Individuals in this group must adhere to the following additional standards

ndash Disclose to the General Counsel and Chief Compliance and Ethics Officer any material transaction or relationship that could reasonably be expected to be a conflict of interest

ndash Provide stakeholders with information that is accurate complete objective fair relevant timely and understandable including information in filings and submissions to the US Securities and Exchange Commission and other regulatory bodies

ndash Act in good faith responsibly with due care competence and diligence without misrepshyresenting material facts or allowing your independent judgment to be compromised

ndash Never mislead or improperly influence any authorized audit or interfere with any auditor engaged in the performance of an internal or independent review of the companyrsquos system of internal controls financial statements or accounting books and records and

ndash Promptly report any possible violation of the companyrsquos Code of Conduct to the General Counsel and Chief Compliance and Ethics Officer

USE OF COMPANY ASSETS Company assets include but are not limited to company funds equipment facilities supplies postal and electronic mail and any type of company-owned information It also includes your time and the time of those with whom you work mdash yoursquore expected to use your time at work responsibly Company assets are to be used for legitimate business purposes and not for your personal gain Yoursquore expected to use good judgment to ensure that assets are not misused or wasted

The companyrsquos name and brand is a vital asset To ensure that we maintain the integrity and value of the brand it is imperative to adhere to the brand guidelines when using the name logo or any reference to the brand Details about the brand and brand guidelines are listed at the Brand Center site on MySource

In addition to keeping within brand guidelines to ensure that the name and brand are used appropriately the following is another important principle to protect these assets You should not imply directly or indirectly any company sponsorship unless you have prior and proper approval This includes refraining from using the companyrsquos name to endorse a client supplier vendor or any third party without the approval of Corporate Marketing You may not proceed with any such use of the companyrsquos name or endorsement without first receiving approval through CODE RAP

(Reference Use of the Companyrsquos Name in Advershytising or Endorsements of Customers and Others)

Careless wasteful inefficient or inappropriate use of any company assets is irresponsible and inconsistent with our Code of Conduct Any type of theft fraud or embezzlement will not be tolerated

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33

PROTECTING CLIENT AND EMPLOYEE RECORDS AND OBSERVING OUR PRIVACY PRINCIPLES The company is responsible for ensuring the privacy confidentiality and controlled access to all client and employee information All of our stakeholders expect us to collect maintain use disseminate and dispose of information only as necessary to carry out responsibilities or as authorized by law

Nearly every employee in the company has access to private information so yoursquore expected to adhere to the following key principles concerning privacy

ndash Collection of client and employee information must be controlled This means that the collection of such information must be permitted under law and only for a legitimate business purpose

ndash Storage and transport of all forms of collected client and employee information must be controlled and safeguarded This means that information collected must be maintained in a secured environment transported by approved vendors and access provided only to those who need to view the information to perform their job duties

ndash Use of client and employee information must be controlled If the law or company policy provides that the client or employee be given a right to ldquoopt-outrdquo of certain uses of information then you must respect that right

ndash Disposal of client and employee information must be controlled You should only retain information for the time period necessary to deliver the service or product and in compliance with applicable retention periods When itrsquos necessary to dispose of information (regardless of the media on which the information is stored) you must do so in a manner appropriate to the sensitivity of the information

ndash Any compromise of client or employee information must be reported If yoursquore aware of or suspect that client or employee information has been lost stolen missing misplaced or misdirected or that therersquos been unauthorized access to information you must immediately report the matter through the companyrsquos incident reporting process

Know how to protect records and make sure to follow company policies at all times The loss of any protected data can be extremely harmful to the company financially and damage our reputation

(Reference Information Privacy Policy Corporate Information Protection Policy)

Q amp A

Q As part of my grouprsquos job duties wersquore able to view the accounts of wealthy clients I overheard one of my colleagues talking to his brother on the phone about the balance in a clientrsquos account that happens to be a very prominent sports figure I donrsquot think this is right but what should I do

A Yoursquore correct in being concerned Your colleague had no right to disclose personal information about a client to anyone who has no legitimate business need for the information File an Incident Report or contact the Ethics Help Line or the Ethics Hot Line to report your concern

34

GLOBAL RECORDS MANAGEMENT PROGRAM You must follow company and local policies for retention management and destruction of records If therersquos an investigation or if litigation is pending or anticipated certain records may need to be retained beyond established destruction periods In most cases yoursquoll be notified of the need to retain documents by the Legal department if appropriate

Records should be defined in the broadest sense mdash meaning that they include any information created or received that has been recorded on any medium or captured in reproducible form Records also include any document that is intentionally retained and managed as final evidence of a business unitrsquos activities events or transactions or for operational legal regulatory or historical purposes

The media and formats of records take many forms including

ndash Papers e-mails instant messages other electronically maintained documents

ndash Microfilms photographs and reproductions

ndash Voice text and audio tapes

ndash Magnetic tapes floppy and hard disks optical disks and drawings and

ndash Any other media regardless of physical form or characteristics that have been made or received in the transaction of business activities

(Reference Records Management Program)

USE OF COMPUTERS SYSTEMS AND CORPORATE INFORMATION As an employee you have access to the companyrsquos computers systems and corporate information to do your job This access means you also have the obligation to use these systems responsibly and follow company policies to protect information and systems

Electronic systems include but are not limited to

ndash Personal computers (including e-mail and instant messages) and computer networks

ndash Telephones cell phones voice mail pagers and fax machines and

ndash Other communications devices such as PDAs (eg Blackberry iPad etc)

Never send sensitive or confidential data over the Internet or over phone systems without following established company policies to protect such information

You should have no expectation of privacy when you use these systems Yoursquore given access only to conduct legitimate company business and yoursquore expected to use them in a professional and responsible manner The company reserves the right to intercept monitor and record your communication on these systems in accordance with the law

Yoursquore expected to protect the security of these systems and follow company policies concerning access and proper use (such as maintaining passwords) In rare cases where there is a necessary and legitimate business reason you may disclose your password to another employee who has the right to access the information associated with your password however you must file a CODE RAP report immediately and observe all necessary steps to restore the confidentiality of your password

KE

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IPLE

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TECTING

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Y ASSETS

35

Yoursquore permitted to use the companyrsquos systems but only if you follow these rules

ndash Messages you create should be professional and appropriate for business communication including those created via e-mail or instant messaging

ndash Never engage in communication that may be considered offensive derogatory obscene vulgar harassing or threatening (eg inappropriate jokes sexual comments or images comments that may offend including those based upon gender race age religious belief sexual orientation gender identity disability or any other basis defined by law)

ndash Do not distribute copyrighted or licensed materials improperly

ndash Do not transmit chain letters advertisements or solicitations (unless theyrsquore specifically authorized by the company)

ndash Never view or download inappropriate materials

The occasional use of company systems for personal purposes is acceptable but yoursquore expected to use good judgment Keep personal use to a minimum Personal use of these systems is a privilege not a right Use them wisely and in a manner that would not damage the companyrsquos reputation

(References Electronic Mail Policy Corporate Information Protection Policy)

Q amp A

Q My co-worker sometimes sends sensitive client data via the Internet to a vendor we use to help solve problems Irsquom concerned because I donrsquot think this information is protected properly He says itrsquos okay because the vendor is authorized to receive the data and the problems that need to be resolved are time-sensitive Should I be worried

A Yes This is a serious matter and you must talk to your manager immediately Your co-worker could be putting clients and BNY Mellon at great risk If you donrsquot raise your concern you may be as responsible as your co-worker for violating company policies If yoursquore uncomfortable raising this issue with your manager file an Incident Report or contact the Ethics Help Line or the Ethics Hot Line to report your concern

36

INSIDE OR PROPRIETARY INFORMATION As an employee you may have knowledge about the companyrsquos businesses or possess confidential information about the private or business affairs of our existing prospective or former clients suppliers vendors and employees You should assume all such information is confidential and privileged and hold it in the strictest confidence Confidential information includes all non-public information that may be of use to competitors or harmful to the company or its clients if disclosed

It is never appropriate to use such information for personal gain or pass it on to anyone outside the company who is not expressly authorized to receive such information Other employees who do not need the information to perform their job duties do not have a right to it Yoursquore expected to protect all such information and failure to do so will not be tolerated

If yoursquore uncertain about whether you have inside or proprietary information you should treat the information as if it were and check with your manager or a representative from the Legal department The following list contains examples of ldquoinsiderdquo or ldquoproprietaryrdquo information

INSIDE INFORMATION Inside information is material non-public information relating to any company including BNY Mellon whose securities trade in a public market Information is deemed to be material if a reasonable investor would likely consider it important when deciding to buy or sell securities of the company or if the information would influence the market price of those securities

Q amp A

Q I discovered that an investor in one of our funds has requested to withdraw a significant amount of money from the fund I manage a clientrsquos money and he has an investment in the same fund To protect my clientrsquos interest I want to pull his money out of the fund because its performance will likely drop Even though the withdrawal is not yet known by the public is this okay because I have a fiduciary duty to my client and Irsquom not benefiting personally by trading on behalf of my client

A No Yoursquore in possession of material nonshypublic information and you may not trade the securities of that fund Your duty to comply with securities laws supersedes any duty you have to your client You should immediately contact the Legal department to discuss this situation

If yoursquore in possession of material non-public information about BNY Mellon or any other company you may not trade the securities of that company for yourself or for others including clients Nearly all countries and jurisdictions have strict securities laws that make you the company and any person with whom you share the information legally responsible for misusing inside information The companyrsquos Securities Firewalls Policy provides instructions on the proper handling of inside information and the company will not tolerate any violation of this policy Certain employees have significant restrictions placed on their trading in BNY Mellon securities or the securities of other companies You must know the restrictions relative to your job and follow company policies and applicable securities laws

KE

Y PR

INC

IPLE

PRO

TECTING

COM

PAN

Y ASSETS

37

PROPRIETARY INFORMATION

Proprietary information includes business plans client lists (prospective and existing) marketing strategies any method of doing business product development plans pricing plans analytical models or methods computer software and related documentation and source code databases inventions ideas and works of authorship Any information inventions models methods ideas software works or materials that you create as part of your job responsibilities or on company time or that you create using information or resources available to you because of your employment by the company or that relate to the business of the company belong to the company exclusively and are considered proprietary information

Proprietary information also includes business contracts invoices statements of work requests for investment or proposal and other similar documents Any information related to a client supplier or vendor financial information (including internal assessments of such) or credit ratings or opinions is considered proprietary You should also assume all information related to client trades non-public portfolio holdings and research reports are proprietary The same is true regarding reports or communications issued by internal auditors external regulators or accountants consultants or any other third-party agent or examiner

Company-produced policies procedures or other similar work materials are proprietary and while they may be shared with other employees they cannot be shared with anyone outside of the company without prior consent of the policy owner and legal counsel

These restrictions on the communication of proprietary information notwithstanding employees are permitted to communicate certain proprietary information to regulatory authorities as detailed in the sections Direct Communication with Government and Regulatory Authorities and Communication of Trade Secrets to Government and Regulatory Authorities above

(References Securities Firewalls Personal Securities Trading Policy Ownership and Protection of Intellectual Property)

Your obligation to protect inside or proprietary information extends beyond the period of your employment with the company The information you use during your employment belongs to the company and you may not take or use this information after you leave the company

38


KE

Y P

RIN

CIP

LE S

UP

PO

RTI

NG

OU

R C

OM

MU

NIT

IES

SUPPORTING OUR COMMUNITIES We take an active part in our communities around the world both as individuals and as a company Our long-term success is linked to the strength of the global economy and the strength of our industry We are honest fair and transparent in every way we interact with our communities and the public at large

POLITICAL ACTIVITIES

INVESTOR AND MEDIA RELATIONS

CHARITABLE CONTRIBUTIONS AND CORPORATE SPONSORSHIP

PARTICIPATING IN TRADE ASSOCIATIONS CONFERENCES AND SPEAKING ENGAGEMENTS

KEY PRINCIPLE SUPPORTING OUR COMMUNITIES

POLITICAL ACTIVITIES PERSONAL POLITICAL ACTIVITY BNY Mellon encourages you to keep informed of political issues and candidates and to take an active interest in political affairs However if you do participate in any political activity you must follow these rules

ndash Never act as a representative of the company unless you have written permission from the Chief Executive Officer the General Counsel and the Chief Compliance and Ethics Officer of the company

ndash Your activities should be on your own time with your own resources You may not use company time equipment facilities supplies clerical support advertising or any other company resources

ndash You may not use company funds for any political activity and you will not be reimbursed or compensated in any way for a political contribution

ndash Your political activities may not affect your objectivity or ability to perform your job duties

ndash You may not solicit the participation of employees clients suppliers vendors or any other party with whom the company does business

ndash You may be required to pre-clear personal political contributions made by you and in some cases your family members

(Reference Political Contributions Policy)

LOBBYING Lobbying is generally defined as any activity that attempts to influence the passage or defeat of legislation Lobbying activities are broad and may cover certain ldquograss rootsrdquo activities where groups of people such as company employees are contacted to encourage them to call public officials for the purpose of influencing legislation Lobbying is prevalent in the US and is gaining influence within the EU and other locations

If you are engaged in lobbying there may be disclosure requirements and restrictions on certain activities If your job duties include any of the following activities you must contact Marketing amp Corporate Affairs or the Legal department for guidance

Q amp A

Q An outside attorney with whom I work from time to time on company business cannot attend an exclusive fundraiser for a high-level political candidate He offered me his ticket The event is to be held at a very wealthy personrsquos home in my community and this will be a great way to solicit business The company is not paying for the ticket and the fundraiser will be on my own time May I attend

A Only if you have the written approval of the Chief Executive Officer the General Counsel and the Chief Compliance and Ethics Officer Your attendance at this event is indirectly related to your job and may give the appearance that yoursquore acting as a representative of the company or that the company sponsors the political candidate It does not matter that BNY Mellon did not purchase the event ticket or that yoursquore going on your own time To the public your attendance is connected to the company So you may not go without obtaining proper authorization prior to the event

39

ndash Government contract sales or marketing

ndash Efforts to influence legislation or administrative actions such as accompanying trade associations in meetings with government officials concerning legislation

ndash Meeting with legislators regulators or their staffs regarding legislation

Lobbying does not include situations where a government agency is seeking public comment on proposed regulations

(Reference Procurement Lobbying)

CORPORATE POLITICAL ACTIVITIES The laws of many countries including the US set strict limits on political contributions made by corporations Contributions are defined broadly to include any form of money purchase of tickets use of company personnel or facilities or payment for services BNY Mellon will make contributions only as permissible by law such as those through company-approved political action committees

Q amp A

Q I have been asked to provide a statement about BNY Mellonrsquos experience with a vendorrsquos product that we use The vendor wants to use my quote on their website or in other marketing materials Is this okay

A It depends Before agreeing to any such arrangement you should contact Corporate Communications BNY Mellon carefully protects its reputation by being highly selective in providing such endorsements Do not proceed until you have the approval of your manager and Corporate Communications

INVESTOR AND MEDIA RELATIONS INVESTOR RELATIONS All contacts with institutional shareholders or securities analysts about the company must be made through the Investor Relations group of the Finance department You must not hold informal or formal discussions with such individuals or groups unless you are specifically authorized to do so Even if you are authorized you cannot provide special access or treatment to shareholders or analysts All investors must have equal access to honest and accurate information

MEDIA RELATIONS Corporate Communications must approve all contacts with the media including speeches testimonials or other public statements made on behalf of the company or about its business You may not respond to any request for interviews comments or information from any television channel radio station newspaper magazine or trade publication either on or off the record unless you have express authorization from Corporate Communications

If you are contacted or interviewed about matters unrelated to your job or to the company you may not identify BNY Mellon as your employer and you may not make comments about BNY Mellon

(Reference Inquiries from the Media Financial Analysts and Securities Holders Use of the Companyrsquos Name in Advertising or Endorsements of Customers and Others)

40

CHARITABLE CONTRIBUTIONS AND CORPORATE SPONSORSHIP The company encourages you to take part in charitable educational fraternal or other civic affairs as long as you follow these basic rules

ndash Your activities may not interfere or in any way conflict with your job duties or with company business

ndash You may not make any gifts or contributions to charities or other entities in the name of or on behalf of the company

ndash You may not imply the companyrsquos sponsorship for or support of any outside event or organization without the approval of the most senior executive of your line of business

ndash You may not use your position for the purpose of soliciting business or contributions for any other entity

ndash You must be cautious in the use of company letterhead facilities or even your business card so that there is no implied or presumed corporate support for non-company business

From time to time the company may agree to sponsor certain charitable events In these situations it may be proper to use company letterhead facilities or other resources (such as employeesrsquo time or company funds) Ask your manager if yoursquore unclear whether or not the event in question is considered to be company sponsored

(Reference Use of the Companyrsquos Name in Advertising or Endorsements of Customers and Others)

PARTICIPATING IN TRADE ASSOCIATIONS CONFERENCES AND SPEAKING ENGAGEMENTS You may participate in trade association meetings and conferences However you must be mindful that these situations often include contact with competitors You must follow the rules related to fair competition and anti-trust referenced in this Code and company policies

In addition meetings where a client vendor or supplier pays for your attendance should be rare and only occur when it is legally allowed in compliance with company policy and pre-approval has been obtained via CODE RAP

If you perform public speaking or writing services on behalf of BNY Mellon any form of compensation accommodations or gift that you or any of your immediate family members receive must be reported through CODE RAP Remember any materials that you may use must not contain any confidential or proprietary information The materials must be approved by the Legal Department and the appropriate level of management that has the topical subject matter expertise


KE

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NITIES

41

ADDITIONAL HELP

This section contains additional questions and answers about the requirements of our Code Remember ignorance or a lack of understanding is not an excuse for violating the Code The company has established many resources to help deal with questions you may have regarding compliance with the Code Yoursquore expected to take advantage of these resources

Q A friend of mine is running for political office and I would like to help her out with her campaign Can I do this

A Yes Your personal support is your personal business Just make sure that you do not use company assets including company time or its name to advance the campaign In addition be aware that certain political contributions must be reported andor pre-cleared

Q I was leaving the office and a journalist asked me if I could answer a few questions I told him no and left the car park but I felt bad about not talking to him Should I have answered his questions

A Not at that time You did the right thing by saying no You should contact Corporate Communications and tell them of the request They will determine whether it will be all right for you to talk to the media If you receive a future request suggest the journalist contact Corporate Communications directly

Q I am running for the local school board and I want to use the office copier to make copies of my campaign flyer Is that okay

A No Company property and equipment may not be used for a political purpose without authorization from Marketing amp Corporate Affairs Running for any public office is considered to be a political purpose Accepting any political appointment or running for office requires approval via CODE RAP

Q To thank a client of mine I want to give him tickets to attend a local football match He mentioned that his company does not permit this type of entertainshyment but I know he would love to go to the match If he doesnrsquot care about his own companyrsquos policy can I give him the tickets

A No If you know that giving him the tickets will violate his own companyrsquos policy do not give the gift Just as we want clients to respect our limits on gifts we must do the same

Q One of the vendors wersquore considering for an assignment offered to take me to a local golf course to play a round and have dinner He wants to talk about his companyrsquos proposal so that we can make a more informed decision Wersquoll be talking about business and there wonrsquot be much money spent on a round of golf and a modest dinner Is this okay

A No Yoursquore evaluating vendors to provide a service Itrsquos always inappropriate to receive or give entertainshyment when the company is in the middle of a selection process

Q One of my vendors offered to send me to a conference at no cost to BNY Mellon Can I accept the invitation

A No Accepting a free trip from a vendor is never permissible If yoursquore interested in attending the conference speak to your manager Most costs associated with your attendance at the conference must be paid by your department Yoursquoll be required to file a CODE RAP form if your manager agrees itrsquos appropriate to attend the conference and yoursquore requesting permission to permit the vendor to pay for part of your conference attendance

42

Q Wersquore entitled to a large payment from a government client if we certify that wersquove met all service level agreements on time Wersquore not sure whether a few very minor items have been completed but theyrsquore not that important to the service Itrsquos close to the end of the quarter and wersquod like to realize the payment Is it okay to send the invoice and certify that the agreements have all been met now

A No You cannot submit the invoice and certificashytion until yoursquore certain that all requirements of the agreement have been met Submission of an incorrect certification could subject the company and you to criminal penalties so it is vitally important that any certification submitted to the government be completely accurate

Q A colleague called while on vacation requesting that I check her e-mail to see if she received an item she was expecting She gave me her logon identificashytion and password requesting that I call her back with the information Can I do this

A No Passwords and other login credentials must be kept confidential and cannot be used by or shared with fellow employees In rare instances when there is a business need that requires you to share your password yoursquore required to file a CODE RAP form immediately afterward

Q I would like to take a part-time job working for my brotherrsquos recycling business His business has no relationship with the company and the work Irsquoll be doing for him is not at all similar to what I do in my job here at the company Can I do this and do I have to file any forms

A Yes you may as long as the time you spend there does not interfere with your job at the company and you donrsquot use any company equipment or supplies You donrsquot need to file a CODE RAP form since yoursquore not the sole proprietor or partial owner of the business However if you work in certain lines of business (such as a broker dealer) you may need to notify Compliance Check with your manager or Compliance officer if yoursquore uncertain

Q I observed a colleague in our supply area filling up a box full of pens paper and other items I asked her what she was doing and she told me that her sonrsquos school was short on supplies so she was trying to help out She said our company can afford the supplies more than her sonrsquos school and that it was the right thing to do I am friendly with my colleague and I donrsquot want to get her in trouble What should I do

A Your colleague is stealing from the company and you must file an Incident Report The supplies purchased by our company are to be used for business needs only Your colleague had no right to take these supplies for any purpose even if it seems like a good cause

REMEMBER All BNY Mellon employees are expected to follow the Code of Conduct even if they disagree with its contents

If faced with a situation in which yoursquore unsure of the correct action to take contact your manager an Ethics Officer Compliance Officer Legal Representative or Human Resources Business Partner for help There are many resources at your disposal to help you Donrsquot hesitate to use them and Do Whatrsquos Right

43

copy2017 The Bank of New York Mellon Corporation All rights reserved PE-1199 012018

rsquo

TABLE OF CONTENTS

CHAIRMANrsquoS LETTER 1

DOING WHATrsquoS RIGHT 2

HOW TO REPORT A CONCERN 3

KEY PRINCIPLES OF OUR CODE 4

WHAT YOU SHOULD KNOW ABOUT OUR

CODE OF CONDUCT 5-9

Our values 5

Purpose of our Code 6

Who must follow this Code 6

Waivers of the Code for executive officers 6

What is expected of employees 7

Cooperating with Regulatory Agencies 8

What is expected of managers 8

Managing risk as a manager 8

Responsibility to ask questions and report concerns 8

What happens when a concern is reported 9

Zero tolerance for retaliation 9

Cooperating with an investigation 9 Direct Communication with Government and Regulatory Authorities 10

Communication of Trade Secrets to Government and Regulatory Authorities 10

RESPECTING OTHERS 12-15

Mutual respect and professional treatment 12

Harassment-free environment 14

Safety and security 15

Managers responsibilities 15

AVOIDING CONFLICTS 16-25

Overview 16

Gifts and entertainment 17

Outside employment and business dealings 20

Outside service as a director officer general partner

political appointment or elected position 22

Ownership of an outside business 23

Fiduciary appointments 23

Personal investment decisions 23

Dealing with family and close personal friends 24

Corporate opportunities 25

CONDUCTING BUSINESS 26-29

Fair competition and anti-trust 26

Anti-corruption and improper payments 28

Combating financial crime and money laundering 29

WORKING WITH GOVERNMENTS 30-31

Your obligations 30

Basic principles 31

PROTECTING COMPANY ASSETS 32-38

Financial integrity 32

Additional standards for senior financial

professionals 33

Use of company assets 33

Protecting client and employee records and observing

our privacy principles 34

Records management 35

Use of computers systems and corporate

information 35

Inside or proprietary information 37

SUPPORTING OUR COMMUNITIES 39-41

Political activities 39

Investor and media relations 40

Charitable contributions and corporate sponsorship 41

Participating in trade associations conferences

and speaking engagements 41

ADDITIONAL HELP 42-43

The Code of Conduct does not alter the terms and conditions of your employment Rather it helps each of us to know what must be done to make sure we always Do Whatrsquos Right The most current version of the Code can be found on MySource

Throughout the Code references to company policies apply only to global policies that cover all employees and do not include additional policies you must follow that are specific to your location or line of business The Code is not intended to fully describe the requirements of referenced policies which can be found in their entirety on MySource


Dear Colleagues






1




business mistake





2
















800-001-0001







3








4











5







6

Q amp A










7

Q amp A

















8

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SAFETY AND SECURITY


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19










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21













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27












28





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29




YOUR OBLIGATIONS

BASIC PRINCIPLES

KE

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31




FINANCIAL INTEGRITY




PRIVACY PRINCIPLES

RECORDS MANAGEMENT



KE

Y PR

INC

IPLE

PR

OTE

CTIN

G C

OM

PAN

Y A

SS

ETS







regulations


Q amp A



32












KE

Y PR

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PAN

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33










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Y PR

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PAN

Y ASSETS

35









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36





Q amp A




KE

Y PR

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Y ASSETS

37








38


KE

Y P

RIN

CIP

LE S

UP

PO

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R C

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IES

















Q amp A



39







Q amp A







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KE

Y PR

INC

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SUPPO

RTIN

G O

UR

COM

MU

NITIES

41

ADDITIONAL HELP














42











43



Dear Colleagues






1




business mistake





2
















800-001-0001







3








4











5







6

Q amp A










7

Q amp A

















8

Q amp A



Q amp A











9










10




SAFETY AND SECURITY


KE

Y PR

INC

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RE

SP

EC

TING

OTH

ER

S






Q amp A



12





KE

Y PR

INC

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G O

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13




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Q amp A



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G O

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15











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16




Q amp A





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17













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NFLICTS

19










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20












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Y PR

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21













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22












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Y PR

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23




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24








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25







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27












28





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29




YOUR OBLIGATIONS

BASIC PRINCIPLES

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WITH

GO

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ME

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MEN

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31




FINANCIAL INTEGRITY




PRIVACY PRINCIPLES

RECORDS MANAGEMENT



KE

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INC

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PAN

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regulations


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33










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34


















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35









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36





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37








38


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Y P

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MU

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41

ADDITIONAL HELP














42











43





business mistake





2
















800-001-0001







3








4











5







6

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7

Q amp A

















8

Q amp A



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10




SAFETY AND SECURITY


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12





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15











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19










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20












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22












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23




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25







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CTING

BU

SINESS

27












28





Q amp A





KE

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INC

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CON

DU

CTING

BU

SINESS

29




YOUR OBLIGATIONS

BASIC PRINCIPLES

KE

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INC

IPLE

WO

RK

ING

WITH

GO

VE

RN

ME

NTS





Q amp A





30

















KE

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INC

IPLE

WO

RK

ING

WITH

GO

VERN

MEN

TS

31




FINANCIAL INTEGRITY




PRIVACY PRINCIPLES

RECORDS MANAGEMENT



KE

Y PR

INC

IPLE

PR

OTE

CTIN

G C

OM

PAN

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SS

ETS







regulations


Q amp A



32












KE

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INC

IPLE

PRO

TECTING

COM

PAN

Y ASSETS

33










Q amp A



34


















KE

Y PR

INC

IPLE

PRO

TECTING

COM

PAN

Y ASSETS

35









Q amp A



36





Q amp A




KE

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INC

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PRO

TECTING

COM

PAN

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37








38


KE

Y P

RIN

CIP

LE S

UP

PO

RTI

NG

OU

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OM

MU

NIT

IES

















Q amp A



39







Q amp A







40













KE

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INC

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SUPPO

RTIN

G O

UR

COM

MU

NITIES

41

ADDITIONAL HELP














42











43

















800-001-0001







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4











5







6

Q amp A










7

Q amp A

















8

Q amp A



Q amp A











9










10




SAFETY AND SECURITY


KE

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INC

IPLE

RE

SP

EC

TING

OTH

ER

S






Q amp A



12





KE

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INC

IPLE

RESPECTIN

G O

THER

S

13




without touching






Q amp A



14







Q amp A






KE

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INC

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RESPECTIN

G O

THER

S

15











KE

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INC

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AV

OID

ING

CO

NF

LICTS







16




Q amp A





KE

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INC

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AVOID

ING

CO

NFLICTS

17













Q amp A



18









Q amp A






KE

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INC

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AVOID

ING

CO

NFLICTS

19










Q amp A



20












KE

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INC

IPLE

AVOID

ING

CO

NFLICTS

21













Q amp A



22












KE

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INC

IPLE

AVOID

ING

CO

NFLICTS

23




Q amp A





24








KE

Y PR

INC

IPLE

AVOID

ING

CO

NFLICTS


25







KE

Y PR

INC

IPLE

CO

ND

UC

TING

BU

SIN

ES

S









ndash Manipulation

ndash Concealment




Q amp A



26








KE

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INC

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CON

DU

CTING

BU

SINESS

27












28





Q amp A





KE

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INC

IPLE

CON

DU

CTING

BU

SINESS

29




YOUR OBLIGATIONS

BASIC PRINCIPLES

KE

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INC

IPLE

WO

RK

ING

WITH

GO

VE

RN

ME

NTS





Q amp A





30

















KE

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INC

IPLE

WO

RK

ING

WITH

GO

VERN

MEN

TS

31




FINANCIAL INTEGRITY




PRIVACY PRINCIPLES

RECORDS MANAGEMENT



KE

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INC

IPLE

PR

OTE

CTIN

G C

OM

PAN

Y A

SS

ETS







regulations


Q amp A



32












KE

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INC

IPLE

PRO

TECTING

COM

PAN

Y ASSETS

33










Q amp A



34


















KE

Y PR

INC

IPLE

PRO

TECTING

COM

PAN

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35









Q amp A



36





Q amp A




KE

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INC

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PRO

TECTING

COM

PAN

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37








38


KE

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RIN

CIP

LE S

UP

PO

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NG

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IES

















Q amp A



39







Q amp A







40













KE

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INC

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SUPPO

RTIN

G O

UR

COM

MU

NITIES

41

ADDITIONAL HELP














42











43









4











5







6

Q amp A










7

Q amp A

















8

Q amp A



Q amp A











9










10




SAFETY AND SECURITY


KE

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INC

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RE

SP

EC

TING

OTH

ER

S






Q amp A



12





KE

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INC

IPLE

RESPECTIN

G O

THER

S

13




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Q amp A



14







Q amp A






KE

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INC

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RESPECTIN

G O

THER

S

15











KE

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INC

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AV

OID

ING

CO

NF

LICTS







16




Q amp A





KE

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INC

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ING

CO

NFLICTS

17













Q amp A



18









Q amp A






KE

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INC

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AVOID

ING

CO

NFLICTS

19










Q amp A



20












KE

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INC

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AVOID

ING

CO

NFLICTS

21













Q amp A



22












KE

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INC

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AVOID

ING

CO

NFLICTS

23




Q amp A





24








KE

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INC

IPLE

AVOID

ING

CO

NFLICTS


25







KE

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INC

IPLE

CO

ND

UC

TING

BU

SIN

ES

S









ndash Manipulation

ndash Concealment




Q amp A



26








KE

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INC

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CON

DU

CTING

BU

SINESS

27












28





Q amp A





KE

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INC

IPLE

CON

DU

CTING

BU

SINESS

29




YOUR OBLIGATIONS

BASIC PRINCIPLES

KE

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INC

IPLE

WO

RK

ING

WITH

GO

VE

RN

ME

NTS





Q amp A





30

















KE

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INC

IPLE

WO

RK

ING

WITH

GO

VERN

MEN

TS

31




FINANCIAL INTEGRITY




PRIVACY PRINCIPLES

RECORDS MANAGEMENT



KE

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INC

IPLE

PR

OTE

CTIN

G C

OM

PAN

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SS

ETS







regulations


Q amp A



32












KE

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INC

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PRO

TECTING

COM

PAN

Y ASSETS

33










Q amp A



34


















KE

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INC

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PRO

TECTING

COM

PAN

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35









Q amp A



36





Q amp A




KE

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INC

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PRO

TECTING

COM

PAN

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37








38


KE

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RIN

CIP

LE S

UP

PO

RTI

NG

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OM

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NIT

IES

















Q amp A



39







Q amp A







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KE

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INC

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SUPPO

RTIN

G O

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COM

MU

NITIES

41

ADDITIONAL HELP














42











43












5







6

Q amp A










7

Q amp A

















8

Q amp A



Q amp A











9










10




SAFETY AND SECURITY


KE

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INC

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RE

SP

EC

TING

OTH

ER

S






Q amp A



12





KE

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INC

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G O

THER

S

13




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Q amp A



14







Q amp A






KE

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INC

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RESPECTIN

G O

THER

S

15











KE

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INC

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AV

OID

ING

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NF

LICTS







16




Q amp A





KE

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INC

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ING

CO

NFLICTS

17













Q amp A



18









Q amp A






KE

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INC

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AVOID

ING

CO

NFLICTS

19










Q amp A



20












KE

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INC

IPLE

AVOID

ING

CO

NFLICTS

21













Q amp A



22












KE

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INC

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AVOID

ING

CO

NFLICTS

23




Q amp A





24








KE

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INC

IPLE

AVOID

ING

CO

NFLICTS


25







KE

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INC

IPLE

CO

ND

UC

TING

BU

SIN

ES

S









ndash Manipulation

ndash Concealment




Q amp A



26








KE

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INC

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CON

DU

CTING

BU

SINESS

27












28





Q amp A





KE

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INC

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CON

DU

CTING

BU

SINESS

29




YOUR OBLIGATIONS

BASIC PRINCIPLES

KE

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INC

IPLE

WO

RK

ING

WITH

GO

VE

RN

ME

NTS





Q amp A





30

















KE

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INC

IPLE

WO

RK

ING

WITH

GO

VERN

MEN

TS

31




FINANCIAL INTEGRITY




PRIVACY PRINCIPLES

RECORDS MANAGEMENT



KE

Y PR

INC

IPLE

PR

OTE

CTIN

G C

OM

PAN

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SS

ETS







regulations


Q amp A



32












KE

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INC

IPLE

PRO

TECTING

COM

PAN

Y ASSETS

33










Q amp A



34


















KE

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INC

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PRO

TECTING

COM

PAN

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35









Q amp A



36





Q amp A




KE

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INC

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PRO

TECTING

COM

PAN

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37








38


KE

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CIP

LE S

UP

PO

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NG

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NIT

IES

















Q amp A



39







Q amp A







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KE

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INC

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SUPPO

RTIN

G O

UR

COM

MU

NITIES

41

ADDITIONAL HELP














42











43








6

Q amp A










7

Q amp A

















8

Q amp A



Q amp A











9










10




SAFETY AND SECURITY


KE

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INC

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RE

SP

EC

TING

OTH

ER

S






Q amp A



12





KE

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INC

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G O

THER

S

13




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Q amp A



14







Q amp A






KE

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INC

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G O

THER

S

15











KE

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INC

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AV

OID

ING

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NF

LICTS







16




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KE

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INC

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ING

CO

NFLICTS

17













Q amp A



18









Q amp A






KE

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INC

IPLE

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ING

CO

NFLICTS

19










Q amp A



20












KE

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INC

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AVOID

ING

CO

NFLICTS

21













Q amp A



22












KE

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INC

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AVOID

ING

CO

NFLICTS

23




Q amp A





24








KE

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INC

IPLE

AVOID

ING

CO

NFLICTS


25







KE

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INC

IPLE

CO

ND

UC

TING

BU

SIN

ES

S









ndash Manipulation

ndash Concealment




Q amp A



26








KE

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INC

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CON

DU

CTING

BU

SINESS

27












28





Q amp A





KE

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INC

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CON

DU

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BU

SINESS

29




YOUR OBLIGATIONS

BASIC PRINCIPLES

KE

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INC

IPLE

WO

RK

ING

WITH

GO

VE

RN

ME

NTS





Q amp A





30

















KE

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INC

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WO

RK

ING

WITH

GO

VERN

MEN

TS

31




FINANCIAL INTEGRITY




PRIVACY PRINCIPLES

RECORDS MANAGEMENT



KE

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INC

IPLE

PR

OTE

CTIN

G C

OM

PAN

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SS

ETS







regulations


Q amp A



32












KE

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INC

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PRO

TECTING

COM

PAN

Y ASSETS

33










Q amp A



34


















KE

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INC

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PRO

TECTING

COM

PAN

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35









Q amp A



36





Q amp A




KE

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INC

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PRO

TECTING

COM

PAN

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37








38


KE

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LE S

UP

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IES

















Q amp A



39







Q amp A







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KE

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INC

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SUPPO

RTIN

G O

UR

COM

MU

NITIES

41

ADDITIONAL HELP














42











43


Q amp A










7

Q amp A

















8

Q amp A



Q amp A











9










10




SAFETY AND SECURITY


KE

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INC

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RE

SP

EC

TING

OTH

ER

S






Q amp A



12





KE

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INC

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G O

THER

S

13




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14







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KE

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INC

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G O

THER

S

15











KE

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INC

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AV

OID

ING

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NF

LICTS







16




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KE

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INC

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ING

CO

NFLICTS

17













Q amp A



18









Q amp A






KE

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INC

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AVOID

ING

CO

NFLICTS

19










Q amp A



20












KE

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INC

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ING

CO

NFLICTS

21













Q amp A



22












KE

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INC

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ING

CO

NFLICTS

23




Q amp A





24








KE

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INC

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AVOID

ING

CO

NFLICTS


25







KE

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INC

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CO

ND

UC

TING

BU

SIN

ES

S









ndash Manipulation

ndash Concealment




Q amp A



26








KE

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INC

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CON

DU

CTING

BU

SINESS

27












28





Q amp A





KE

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INC

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CON

DU

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BU

SINESS

29




YOUR OBLIGATIONS

BASIC PRINCIPLES

KE

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INC

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WO

RK

ING

WITH

GO

VE

RN

ME

NTS





Q amp A





30

















KE

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INC

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WO

RK

ING

WITH

GO

VERN

MEN

TS

31




FINANCIAL INTEGRITY




PRIVACY PRINCIPLES

RECORDS MANAGEMENT



KE

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INC

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PR

OTE

CTIN

G C

OM

PAN

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SS

ETS







regulations


Q amp A



32












KE

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INC

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PRO

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COM

PAN

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33










Q amp A



34


















KE

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INC

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PRO

TECTING

COM

PAN

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35









Q amp A



36





Q amp A




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INC

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PRO

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COM

PAN

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37








38


KE

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RIN

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LE S

UP

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NG

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NIT

IES

















Q amp A



39







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KE

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INC

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SUPPO

RTIN

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UR

COM

MU

NITIES

41

ADDITIONAL HELP














42











43


Q amp A

















8

Q amp A



Q amp A











9










10




SAFETY AND SECURITY


KE

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INC

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RE

SP

EC

TING

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ER

S






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12





KE

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INC

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THER

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13




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14







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THER

S

15











KE

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INC

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AV

OID

ING

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NF

LICTS







16




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KE

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ING

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NFLICTS

17













Q amp A



18









Q amp A






KE

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INC

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ING

CO

NFLICTS

19










Q amp A



20












KE

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INC

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ING

CO

NFLICTS

21













Q amp A



22












KE

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INC

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ING

CO

NFLICTS

23




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24








KE

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INC

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ING

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NFLICTS


25







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INC

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CO

ND

UC

TING

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SIN

ES

S









ndash Manipulation

ndash Concealment




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26








KE

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INC

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DU

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BU

SINESS

27












28





Q amp A





KE

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INC

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CON

DU

CTING

BU

SINESS

29




YOUR OBLIGATIONS

BASIC PRINCIPLES

KE

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INC

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WO

RK

ING

WITH

GO

VE

RN

ME

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Q amp A





30

















KE

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INC

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WO

RK

ING

WITH

GO

VERN

MEN

TS

31




FINANCIAL INTEGRITY




PRIVACY PRINCIPLES

RECORDS MANAGEMENT



KE

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INC

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PR

OTE

CTIN

G C

OM

PAN

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SS

ETS







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Q amp A



32












KE

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INC

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PRO

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COM

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33










Q amp A



34


















KE

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INC

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COM

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35









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36





Q amp A




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INC

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37








38


KE

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LE S

UP

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NIT

IES

















Q amp A



39







Q amp A







40













KE

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INC

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RTIN

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UR

COM

MU

NITIES

41

ADDITIONAL HELP














42











43


Q amp A



Q amp A











9










10




SAFETY AND SECURITY


KE

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INC

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RE

SP

EC

TING

OTH

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S






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12





KE

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INC

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THER

S

13




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14







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THER

S

15











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INC

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OID

ING

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LICTS







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KE

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ING

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17













Q amp A



18









Q amp A






KE

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INC

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ING

CO

NFLICTS

19










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20












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INC

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ING

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NFLICTS

21













Q amp A



22












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INC

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ING

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NFLICTS

23




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24








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INC

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ING

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25







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INC

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CO

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UC

TING

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SIN

ES

S









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ndash Concealment




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26








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INC

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CTING

BU

SINESS

27












28





Q amp A





KE

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INC

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CON

DU

CTING

BU

SINESS

29




YOUR OBLIGATIONS

BASIC PRINCIPLES

KE

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INC

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WO

RK

ING

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VE

RN

ME

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Q amp A





30

















KE

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INC

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WO

RK

ING

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GO

VERN

MEN

TS

31




FINANCIAL INTEGRITY




PRIVACY PRINCIPLES

RECORDS MANAGEMENT



KE

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INC

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PR

OTE

CTIN

G C

OM

PAN

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SS

ETS







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Q amp A



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KE

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INC

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34


















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35









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INC

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37








38


KE

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LE S

UP

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IES

















Q amp A



39







Q amp A







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KE

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INC

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RTIN

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UR

COM

MU

NITIES

41

ADDITIONAL HELP














42











43











10




SAFETY AND SECURITY


KE

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INC

IPLE

RE

SP

EC

TING

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ER

S






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12





KE

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INC

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THER

S

13




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14







Q amp A






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THER

S

15











KE

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INC

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OID

ING

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NF

LICTS







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KE

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ING

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NFLICTS

17













Q amp A



18









Q amp A






KE

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INC

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ING

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NFLICTS

19










Q amp A



20












KE

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INC

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ING

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21













Q amp A



22












KE

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INC

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ING

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23




Q amp A





24








KE

Y PR

INC

IPLE

AVOID

ING

CO

NFLICTS


25







KE

Y PR

INC

IPLE

CO

ND

UC

TING

BU

SIN

ES

S









ndash Manipulation

ndash Concealment




Q amp A



26








KE

Y PR

INC

IPLE

CON

DU

CTING

BU

SINESS

27












28





Q amp A





KE

Y PR

INC

IPLE

CON

DU

CTING

BU

SINESS

29




YOUR OBLIGATIONS

BASIC PRINCIPLES

KE

Y PR

INC

IPLE

WO

RK

ING

WITH

GO

VE

RN

ME

NTS





Q amp A





30

















KE

Y PR

INC

IPLE

WO

RK

ING

WITH

GO

VERN

MEN

TS

31




FINANCIAL INTEGRITY




PRIVACY PRINCIPLES

RECORDS MANAGEMENT



KE

Y PR

INC

IPLE

PR

OTE

CTIN

G C

OM

PAN

Y A

SS

ETS







regulations


Q amp A



32












KE

Y PR

INC

IPLE

PRO

TECTING

COM

PAN

Y ASSETS

33










Q amp A



34


















KE

Y PR

INC

IPLE

PRO

TECTING

COM

PAN

Y ASSETS

35









Q amp A



36





Q amp A




KE

Y PR

INC

IPLE

PRO

TECTING

COM

PAN

Y ASSETS

37








38


KE

Y P

RIN

CIP

LE S

UP

PO

RTI

NG

OU

R C

OM

MU

NIT

IES

















Q amp A



39







Q amp A







40













KE

Y PR

INC

IPLE

SUPPO

RTIN

G O

UR

COM

MU

NITIES

41

ADDITIONAL HELP














42











43





SAFETY AND SECURITY


KE

Y PR

INC

IPLE

RE

SP

EC

TING

OTH

ER

S






Q amp A



12





KE

Y PR

INC

IPLE

RESPECTIN

G O

THER

S

13




without touching






Q amp A



14







Q amp A






KE

Y PR

INC

IPLE

RESPECTIN

G O

THER

S

15











KE

Y PR

INC

IPLE

AV

OID

ING

CO

NF

LICTS







16




Q amp A





KE

Y PR

INC

IPLE

AVOID

ING

CO

NFLICTS

17













Q amp A



18









Q amp A






KE

Y PR

INC

IPLE

AVOID

ING

CO

NFLICTS

19










Q amp A



20












KE

Y PR

INC

IPLE

AVOID

ING

CO

NFLICTS

21













Q amp A



22












KE

Y PR

INC

IPLE

AVOID

ING

CO

NFLICTS

23




Q amp A





24








KE

Y PR

INC

IPLE

AVOID

ING

CO

NFLICTS


25







KE

Y PR

INC

IPLE

CO

ND

UC

TING

BU

SIN

ES

S









ndash Manipulation

ndash Concealment




Q amp A



26








KE

Y PR

INC

IPLE

CON

DU

CTING

BU

SINESS

27












28





Q amp A





KE

Y PR

INC

IPLE

CON

DU

CTING

BU

SINESS

29




YOUR OBLIGATIONS

BASIC PRINCIPLES

KE

Y PR

INC

IPLE

WO

RK

ING

WITH

GO

VE

RN

ME

NTS





Q amp A





30

















KE

Y PR

INC

IPLE

WO

RK

ING

WITH

GO

VERN

MEN

TS

31




FINANCIAL INTEGRITY




PRIVACY PRINCIPLES

RECORDS MANAGEMENT



KE

Y PR

INC

IPLE

PR

OTE

CTIN

G C

OM

PAN

Y A

SS

ETS







regulations


Q amp A



32












KE

Y PR

INC

IPLE

PRO

TECTING

COM

PAN

Y ASSETS

33










Q amp A



34


















KE

Y PR

INC

IPLE

PRO

TECTING

COM

PAN

Y ASSETS

35









Q amp A



36





Q amp A




KE

Y PR

INC

IPLE

PRO

TECTING

COM

PAN

Y ASSETS

37








38


KE

Y P

RIN

CIP

LE S

UP

PO

RTI

NG

OU

R C

OM

MU

NIT

IES

















Q amp A



39







Q amp A







40













KE

Y PR

INC

IPLE

SUPPO

RTIN

G O

UR

COM

MU

NITIES

41

ADDITIONAL HELP














42











43







Q amp A



12





KE

Y PR

INC

IPLE

RESPECTIN

G O

THER

S

13




without touching






Q amp A



14







Q amp A






KE

Y PR

INC

IPLE

RESPECTIN

G O

THER

S

15











KE

Y PR

INC

IPLE

AV

OID

ING

CO

NF

LICTS







16




Q amp A





KE

Y PR

INC

IPLE

AVOID

ING

CO

NFLICTS

17













Q amp A



18









Q amp A






KE

Y PR

INC

IPLE

AVOID

ING

CO

NFLICTS

19










Q amp A



20












KE

Y PR

INC

IPLE

AVOID

ING

CO

NFLICTS

21













Q amp A



22












KE

Y PR

INC

IPLE

AVOID

ING

CO

NFLICTS

23




Q amp A





24








KE

Y PR

INC

IPLE

AVOID

ING

CO

NFLICTS


25







KE

Y PR

INC

IPLE

CO

ND

UC

TING

BU

SIN

ES

S









ndash Manipulation

ndash Concealment




Q amp A



26








KE

Y PR

INC

IPLE

CON

DU

CTING

BU

SINESS

27












28





Q amp A





KE

Y PR

INC

IPLE

CON

DU

CTING

BU

SINESS

29




YOUR OBLIGATIONS

BASIC PRINCIPLES

KE

Y PR

INC

IPLE

WO

RK

ING

WITH

GO

VE

RN

ME

NTS





Q amp A





30

















KE

Y PR

INC

IPLE

WO

RK

ING

WITH

GO

VERN

MEN

TS

31




FINANCIAL INTEGRITY




PRIVACY PRINCIPLES

RECORDS MANAGEMENT



KE

Y PR

INC

IPLE

PR

OTE

CTIN

G C

OM

PAN

Y A

SS

ETS







regulations


Q amp A



32












KE

Y PR

INC

IPLE

PRO

TECTING

COM

PAN

Y ASSETS

33










Q amp A



34


















KE

Y PR

INC

IPLE

PRO

TECTING

COM

PAN

Y ASSETS

35









Q amp A



36





Q amp A




KE

Y PR

INC

IPLE

PRO

TECTING

COM

PAN

Y ASSETS

37








38


KE

Y P

RIN

CIP

LE S

UP

PO

RTI

NG

OU

R C

OM

MU

NIT

IES

















Q amp A



39







Q amp A







40













KE

Y PR

INC

IPLE

SUPPO

RTIN

G O

UR

COM

MU

NITIES

41

ADDITIONAL HELP














42











43






KE

Y PR

INC

IPLE

RESPECTIN

G O

THER

S

13




without touching






Q amp A



14







Q amp A






KE

Y PR

INC

IPLE

RESPECTIN

G O

THER

S

15











KE

Y PR

INC

IPLE

AV

OID

ING

CO

NF

LICTS







16




Q amp A





KE

Y PR

INC

IPLE

AVOID

ING

CO

NFLICTS

17













Q amp A



18









Q amp A






KE

Y PR

INC

IPLE

AVOID

ING

CO

NFLICTS

19










Q amp A



20












KE

Y PR

INC

IPLE

AVOID

ING

CO

NFLICTS

21













Q amp A



22












KE

Y PR

INC

IPLE

AVOID

ING

CO

NFLICTS

23




Q amp A





24








KE

Y PR

INC

IPLE

AVOID

ING

CO

NFLICTS


25







KE

Y PR

INC

IPLE

CO

ND

UC

TING

BU

SIN

ES

S









ndash Manipulation

ndash Concealment




Q amp A



26








KE

Y PR

INC

IPLE

CON

DU

CTING

BU

SINESS

27












28





Q amp A





KE

Y PR

INC

IPLE

CON

DU

CTING

BU

SINESS

29




YOUR OBLIGATIONS

BASIC PRINCIPLES

KE

Y PR

INC

IPLE

WO

RK

ING

WITH

GO

VE

RN

ME

NTS





Q amp A





30

















KE

Y PR

INC

IPLE

WO

RK

ING

WITH

GO

VERN

MEN

TS

31




FINANCIAL INTEGRITY




PRIVACY PRINCIPLES

RECORDS MANAGEMENT



KE

Y PR

INC

IPLE

PR

OTE

CTIN

G C

OM

PAN

Y A

SS

ETS







regulations


Q amp A



32












KE

Y PR

INC

IPLE

PRO

TECTING

COM

PAN

Y ASSETS

33










Q amp A



34


















KE

Y PR

INC

IPLE

PRO

TECTING

COM

PAN

Y ASSETS

35









Q amp A



36





Q amp A




KE

Y PR

INC

IPLE

PRO

TECTING

COM

PAN

Y ASSETS

37








38


KE

Y P

RIN

CIP

LE S

UP

PO

RTI

NG

OU

R C

OM

MU

NIT

IES

















Q amp A



39







Q amp A







40













KE

Y PR

INC

IPLE

SUPPO

RTIN

G O

UR

COM

MU

NITIES

41

ADDITIONAL HELP














42











43





without touching






Q amp A



14







Q amp A






KE

Y PR

INC

IPLE

RESPECTIN

G O

THER

S

15











KE

Y PR

INC

IPLE

AV

OID

ING

CO

NF

LICTS







16




Q amp A





KE

Y PR

INC

IPLE

AVOID

ING

CO

NFLICTS

17













Q amp A



18









Q amp A






KE

Y PR

INC

IPLE

AVOID

ING

CO

NFLICTS

19










Q amp A



20












KE

Y PR

INC

IPLE

AVOID

ING

CO

NFLICTS

21













Q amp A



22












KE

Y PR

INC

IPLE

AVOID

ING

CO

NFLICTS

23




Q amp A





24








KE

Y PR

INC

IPLE

AVOID

ING

CO

NFLICTS


25







KE

Y PR

INC

IPLE

CO

ND

UC

TING

BU

SIN

ES

S









ndash Manipulation

ndash Concealment




Q amp A



26








KE

Y PR

INC

IPLE

CON

DU

CTING

BU

SINESS

27












28





Q amp A





KE

Y PR

INC

IPLE

CON

DU

CTING

BU

SINESS

29




YOUR OBLIGATIONS

BASIC PRINCIPLES

KE

Y PR

INC

IPLE

WO

RK

ING

WITH

GO

VE

RN

ME

NTS





Q amp A





30

















KE

Y PR

INC

IPLE

WO

RK

ING

WITH

GO

VERN

MEN

TS

31




FINANCIAL INTEGRITY




PRIVACY PRINCIPLES

RECORDS MANAGEMENT



KE

Y PR

INC

IPLE

PR

OTE

CTIN

G C

OM

PAN

Y A

SS

ETS







regulations


Q amp A



32












KE

Y PR

INC

IPLE

PRO

TECTING

COM

PAN

Y ASSETS

33










Q amp A



34


















KE

Y PR

INC

IPLE

PRO

TECTING

COM

PAN

Y ASSETS

35









Q amp A



36





Q amp A




KE

Y PR

INC

IPLE

PRO

TECTING

COM

PAN

Y ASSETS

37








38


KE

Y P

RIN

CIP

LE S

UP

PO

RTI

NG

OU

R C

OM

MU

NIT

IES

















Q amp A



39







Q amp A







40













KE

Y PR

INC

IPLE

SUPPO

RTIN

G O

UR

COM

MU

NITIES

41

ADDITIONAL HELP














42











43








Q amp A






KE

Y PR

INC

IPLE

RESPECTIN

G O

THER

S

15











KE

Y PR

INC

IPLE

AV

OID

ING

CO

NF

LICTS







16




Q amp A





KE

Y PR

INC

IPLE

AVOID

ING

CO

NFLICTS

17













Q amp A



18









Q amp A






KE

Y PR

INC

IPLE

AVOID

ING

CO

NFLICTS

19










Q amp A



20












KE

Y PR

INC

IPLE

AVOID

ING

CO

NFLICTS

21













Q amp A



22












KE

Y PR

INC

IPLE

AVOID

ING

CO

NFLICTS

23




Q amp A





24








KE

Y PR

INC

IPLE

AVOID

ING

CO

NFLICTS


25







KE

Y PR

INC

IPLE

CO

ND

UC

TING

BU

SIN

ES

S









ndash Manipulation

ndash Concealment




Q amp A



26








KE

Y PR

INC

IPLE

CON

DU

CTING

BU

SINESS

27












28





Q amp A





KE

Y PR

INC

IPLE

CON

DU

CTING

BU

SINESS

29




YOUR OBLIGATIONS

BASIC PRINCIPLES

KE

Y PR

INC

IPLE

WO

RK

ING

WITH

GO

VE

RN

ME

NTS





Q amp A





30

















KE

Y PR

INC

IPLE

WO

RK

ING

WITH

GO

VERN

MEN

TS

31




FINANCIAL INTEGRITY




PRIVACY PRINCIPLES

RECORDS MANAGEMENT



KE

Y PR

INC

IPLE

PR

OTE

CTIN

G C

OM

PAN

Y A

SS

ETS







regulations


Q amp A



32












KE

Y PR

INC

IPLE

PRO

TECTING

COM

PAN

Y ASSETS

33










Q amp A



34


















KE

Y PR

INC

IPLE

PRO

TECTING

COM

PAN

Y ASSETS

35









Q amp A



36





Q amp A




KE

Y PR

INC

IPLE

PRO

TECTING

COM

PAN

Y ASSETS

37








38


KE

Y P

RIN

CIP

LE S

UP

PO

RTI

NG

OU

R C

OM

MU

NIT

IES

















Q amp A



39







Q amp A







40













KE

Y PR

INC

IPLE

SUPPO

RTIN

G O

UR

COM

MU

NITIES

41

ADDITIONAL HELP














42











43












KE

Y PR

INC

IPLE

AV

OID

ING

CO

NF

LICTS







16




Q amp A





KE

Y PR

INC

IPLE

AVOID

ING

CO

NFLICTS

17













Q amp A



18









Q amp A






KE

Y PR

INC

IPLE

AVOID

ING

CO

NFLICTS

19










Q amp A



20












KE

Y PR

INC

IPLE

AVOID

ING

CO

NFLICTS

21













Q amp A



22












KE

Y PR

INC

IPLE

AVOID

ING

CO

NFLICTS

23




Q amp A





24








KE

Y PR

INC

IPLE

AVOID

ING

CO

NFLICTS


25







KE

Y PR

INC

IPLE

CO

ND

UC

TING

BU

SIN

ES

S









ndash Manipulation

ndash Concealment




Q amp A



26








KE

Y PR

INC

IPLE

CON

DU

CTING

BU

SINESS

27












28





Q amp A





KE

Y PR

INC

IPLE

CON

DU

CTING

BU

SINESS

29




YOUR OBLIGATIONS

BASIC PRINCIPLES

KE

Y PR

INC

IPLE

WO

RK

ING

WITH

GO

VE

RN

ME

NTS





Q amp A





30

















KE

Y PR

INC

IPLE

WO

RK

ING

WITH

GO

VERN

MEN

TS

31




FINANCIAL INTEGRITY




PRIVACY PRINCIPLES

RECORDS MANAGEMENT



KE

Y PR

INC

IPLE

PR

OTE

CTIN

G C

OM

PAN

Y A

SS

ETS







regulations


Q amp A



32












KE

Y PR

INC

IPLE

PRO

TECTING

COM

PAN

Y ASSETS

33










Q amp A



34


















KE

Y PR

INC

IPLE

PRO

TECTING

COM

PAN

Y ASSETS

35









Q amp A



36





Q amp A




KE

Y PR

INC

IPLE

PRO

TECTING

COM

PAN

Y ASSETS

37








38


KE

Y P

RIN

CIP

LE S

UP

PO

RTI

NG

OU

R C

OM

MU

NIT

IES

















Q amp A



39







Q amp A







40













KE

Y PR

INC

IPLE

SUPPO

RTIN

G O

UR

COM

MU

NITIES

41

ADDITIONAL HELP














42











43











KE

Y PR

INC

IPLE

AV

OID

ING

CO

NF

LICTS







16




Q amp A





KE

Y PR

INC

IPLE

AVOID

ING

CO

NFLICTS

17













Q amp A



18









Q amp A






KE

Y PR

INC

IPLE

AVOID

ING

CO

NFLICTS

19










Q amp A



20












KE

Y PR

INC

IPLE

AVOID

ING

CO

NFLICTS

21













Q amp A



22












KE

Y PR

INC

IPLE

AVOID

ING

CO

NFLICTS

23




Q amp A





24








KE

Y PR

INC

IPLE

AVOID

ING

CO

NFLICTS


25







KE

Y PR

INC

IPLE

CO

ND

UC

TING

BU

SIN

ES

S









ndash Manipulation

ndash Concealment




Q amp A



26








KE

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INC

IPLE

CON

DU

CTING

BU

SINESS

27












28





Q amp A





KE

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INC

IPLE

CON

DU

CTING

BU

SINESS

29




YOUR OBLIGATIONS

BASIC PRINCIPLES

KE

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INC

IPLE

WO

RK

ING

WITH

GO

VE

RN

ME

NTS





Q amp A





30

















KE

Y PR

INC

IPLE

WO

RK

ING

WITH

GO

VERN

MEN

TS

31




FINANCIAL INTEGRITY




PRIVACY PRINCIPLES

RECORDS MANAGEMENT



KE

Y PR

INC

IPLE

PR

OTE

CTIN

G C

OM

PAN

Y A

SS

ETS







regulations


Q amp A



32












KE

Y PR

INC

IPLE

PRO

TECTING

COM

PAN

Y ASSETS

33










Q amp A



34


















KE

Y PR

INC

IPLE

PRO

TECTING

COM

PAN

Y ASSETS

35









Q amp A



36





Q amp A




KE

Y PR

INC

IPLE

PRO

TECTING

COM

PAN

Y ASSETS

37








38


KE

Y P

RIN

CIP

LE S

UP

PO

RTI

NG

OU

R C

OM

MU

NIT

IES

















Q amp A



39







Q amp A







40













KE

Y PR

INC

IPLE

SUPPO

RTIN

G O

UR

COM

MU

NITIES

41

ADDITIONAL HELP














42











43








16




Q amp A





KE

Y PR

INC

IPLE

AVOID

ING

CO

NFLICTS

17













Q amp A



18









Q amp A






KE

Y PR

INC

IPLE

AVOID

ING

CO

NFLICTS

19










Q amp A



20












KE

Y PR

INC

IPLE

AVOID

ING

CO

NFLICTS

21













Q amp A



22












KE

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INC

IPLE

AVOID

ING

CO

NFLICTS

23




Q amp A





24








KE

Y PR

INC

IPLE

AVOID

ING

CO

NFLICTS


25







KE

Y PR

INC

IPLE

CO

ND

UC

TING

BU

SIN

ES

S









ndash Manipulation

ndash Concealment




Q amp A



26








KE

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INC

IPLE

CON

DU

CTING

BU

SINESS

27












28





Q amp A





KE

Y PR

INC

IPLE

CON

DU

CTING

BU

SINESS

29




YOUR OBLIGATIONS

BASIC PRINCIPLES

KE

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INC

IPLE

WO

RK

ING

WITH

GO

VE

RN

ME

NTS





Q amp A





30

















KE

Y PR

INC

IPLE

WO

RK

ING

WITH

GO

VERN

MEN

TS

31




FINANCIAL INTEGRITY




PRIVACY PRINCIPLES

RECORDS MANAGEMENT



KE

Y PR

INC

IPLE

PR

OTE

CTIN

G C

OM

PAN

Y A

SS

ETS







regulations


Q amp A



32












KE

Y PR

INC

IPLE

PRO

TECTING

COM

PAN

Y ASSETS

33










Q amp A



34


















KE

Y PR

INC

IPLE

PRO

TECTING

COM

PAN

Y ASSETS

35









Q amp A



36





Q amp A




KE

Y PR

INC

IPLE

PRO

TECTING

COM

PAN

Y ASSETS

37








38


KE

Y P

RIN

CIP

LE S

UP

PO

RTI

NG

OU

R C

OM

MU

NIT

IES

















Q amp A



39







Q amp A







40













KE

Y PR

INC

IPLE

SUPPO

RTIN

G O

UR

COM

MU

NITIES

41

ADDITIONAL HELP














42











43





Q amp A





KE

Y PR

INC

IPLE

AVOID

ING

CO

NFLICTS

17













Q amp A



18









Q amp A






KE

Y PR

INC

IPLE

AVOID

ING

CO

NFLICTS

19










Q amp A



20












KE

Y PR

INC

IPLE

AVOID

ING

CO

NFLICTS

21













Q amp A



22












KE

Y PR

INC

IPLE

AVOID

ING

CO

NFLICTS

23




Q amp A





24








KE

Y PR

INC

IPLE

AVOID

ING

CO

NFLICTS


25







KE

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INC

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CO

ND

UC

TING

BU

SIN

ES

S









ndash Manipulation

ndash Concealment




Q amp A



26








KE

Y PR

INC

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CON

DU

CTING

BU

SINESS

27












28





Q amp A





KE

Y PR

INC

IPLE

CON

DU

CTING

BU

SINESS

29




YOUR OBLIGATIONS

BASIC PRINCIPLES

KE

Y PR

INC

IPLE

WO

RK

ING

WITH

GO

VE

RN

ME

NTS





Q amp A





30

















KE

Y PR

INC

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WO

RK

ING

WITH

GO

VERN

MEN

TS

31




FINANCIAL INTEGRITY




PRIVACY PRINCIPLES

RECORDS MANAGEMENT



KE

Y PR

INC

IPLE

PR

OTE

CTIN

G C

OM

PAN

Y A

SS

ETS







regulations


Q amp A



32












KE

Y PR

INC

IPLE

PRO

TECTING

COM

PAN

Y ASSETS

33










Q amp A



34


















KE

Y PR

INC

IPLE

PRO

TECTING

COM

PAN

Y ASSETS

35









Q amp A



36





Q amp A




KE

Y PR

INC

IPLE

PRO

TECTING

COM

PAN

Y ASSETS

37








38


KE

Y P

RIN

CIP

LE S

UP

PO

RTI

NG

OU

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OM

MU

NIT

IES

















Q amp A



39







Q amp A







40













KE

Y PR

INC

IPLE

SUPPO

RTIN

G O

UR

COM

MU

NITIES

41

ADDITIONAL HELP














42











43














Q amp A



18









Q amp A






KE

Y PR

INC

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AVOID

ING

CO

NFLICTS

19










Q amp A



20












KE

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INC

IPLE

AVOID

ING

CO

NFLICTS

21













Q amp A



22












KE

Y PR

INC

IPLE

AVOID

ING

CO

NFLICTS

23




Q amp A





24








KE

Y PR

INC

IPLE

AVOID

ING

CO

NFLICTS


25







KE

Y PR

INC

IPLE

CO

ND

UC

TING

BU

SIN

ES

S









ndash Manipulation

ndash Concealment




Q amp A



26








KE

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INC

IPLE

CON

DU

CTING

BU

SINESS

27












28





Q amp A





KE

Y PR

INC

IPLE

CON

DU

CTING

BU

SINESS

29




YOUR OBLIGATIONS

BASIC PRINCIPLES

KE

Y PR

INC

IPLE

WO

RK

ING

WITH

GO

VE

RN

ME

NTS





Q amp A





30

















KE

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INC

IPLE

WO

RK

ING

WITH

GO

VERN

MEN

TS

31




FINANCIAL INTEGRITY




PRIVACY PRINCIPLES

RECORDS MANAGEMENT



KE

Y PR

INC

IPLE

PR

OTE

CTIN

G C

OM

PAN

Y A

SS

ETS







regulations


Q amp A



32












KE

Y PR

INC

IPLE

PRO

TECTING

COM

PAN

Y ASSETS

33










Q amp A



34


















KE

Y PR

INC

IPLE

PRO

TECTING

COM

PAN

Y ASSETS

35









Q amp A



36





Q amp A




KE

Y PR

INC

IPLE

PRO

TECTING

COM

PAN

Y ASSETS

37








38


KE

Y P

RIN

CIP

LE S

UP

PO

RTI

NG

OU

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OM

MU

NIT

IES

















Q amp A



39







Q amp A







40













KE

Y PR

INC

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SUPPO

RTIN

G O

UR

COM

MU

NITIES

41

ADDITIONAL HELP














42











43










Q amp A






KE

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INC

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AVOID

ING

CO

NFLICTS

19










Q amp A



20












KE

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INC

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AVOID

ING

CO

NFLICTS

21













Q amp A



22












KE

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INC

IPLE

AVOID

ING

CO

NFLICTS

23




Q amp A





24








KE

Y PR

INC

IPLE

AVOID

ING

CO

NFLICTS


25







KE

Y PR

INC

IPLE

CO

ND

UC

TING

BU

SIN

ES

S









ndash Manipulation

ndash Concealment




Q amp A



26








KE

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INC

IPLE

CON

DU

CTING

BU

SINESS

27












28





Q amp A





KE

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INC

IPLE

CON

DU

CTING

BU

SINESS

29




YOUR OBLIGATIONS

BASIC PRINCIPLES

KE

Y PR

INC

IPLE

WO

RK

ING

WITH

GO

VE

RN

ME

NTS





Q amp A





30

















KE

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INC

IPLE

WO

RK

ING

WITH

GO

VERN

MEN

TS

31




FINANCIAL INTEGRITY




PRIVACY PRINCIPLES

RECORDS MANAGEMENT



KE

Y PR

INC

IPLE

PR

OTE

CTIN

G C

OM

PAN

Y A

SS

ETS







regulations


Q amp A



32












KE

Y PR

INC

IPLE

PRO

TECTING

COM

PAN

Y ASSETS

33










Q amp A



34


















KE

Y PR

INC

IPLE

PRO

TECTING

COM

PAN

Y ASSETS

35









Q amp A



36





Q amp A




KE

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INC

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PRO

TECTING

COM

PAN

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37








38


KE

Y P

RIN

CIP

LE S

UP

PO

RTI

NG

OU

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OM

MU

NIT

IES

















Q amp A



39







Q amp A







40













KE

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INC

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SUPPO

RTIN

G O

UR

COM

MU

NITIES

41

ADDITIONAL HELP














42











43











Q amp A



20












KE

Y PR

INC

IPLE

AVOID

ING

CO

NFLICTS

21













Q amp A



22












KE

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INC

IPLE

AVOID

ING

CO

NFLICTS

23




Q amp A





24








KE

Y PR

INC

IPLE

AVOID

ING

CO

NFLICTS


25







KE

Y PR

INC

IPLE

CO

ND

UC

TING

BU

SIN

ES

S









ndash Manipulation

ndash Concealment




Q amp A



26








KE

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INC

IPLE

CON

DU

CTING

BU

SINESS

27












28





Q amp A





KE

Y PR

INC

IPLE

CON

DU

CTING

BU

SINESS

29




YOUR OBLIGATIONS

BASIC PRINCIPLES

KE

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INC

IPLE

WO

RK

ING

WITH

GO

VE

RN

ME

NTS





Q amp A





30

















KE

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INC

IPLE

WO

RK

ING

WITH

GO

VERN

MEN

TS

31




FINANCIAL INTEGRITY




PRIVACY PRINCIPLES

RECORDS MANAGEMENT



KE

Y PR

INC

IPLE

PR

OTE

CTIN

G C

OM

PAN

Y A

SS

ETS







regulations


Q amp A



32












KE

Y PR

INC

IPLE

PRO

TECTING

COM

PAN

Y ASSETS

33










Q amp A



34


















KE

Y PR

INC

IPLE

PRO

TECTING

COM

PAN

Y ASSETS

35









Q amp A



36





Q amp A




KE

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INC

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PRO

TECTING

COM

PAN

Y ASSETS

37








38


KE

Y P

RIN

CIP

LE S

UP

PO

RTI

NG

OU

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OM

MU

NIT

IES

















Q amp A



39







Q amp A







40













KE

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INC

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SUPPO

RTIN

G O

UR

COM

MU

NITIES

41

ADDITIONAL HELP














42











43













KE

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INC

IPLE

AVOID

ING

CO

NFLICTS

21













Q amp A



22












KE

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INC

IPLE

AVOID

ING

CO

NFLICTS

23




Q amp A





24








KE

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INC

IPLE

AVOID

ING

CO

NFLICTS


25







KE

Y PR

INC

IPLE

CO

ND

UC

TING

BU

SIN

ES

S









ndash Manipulation

ndash Concealment




Q amp A



26








KE

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INC

IPLE

CON

DU

CTING

BU

SINESS

27












28





Q amp A





KE

Y PR

INC

IPLE

CON

DU

CTING

BU

SINESS

29




YOUR OBLIGATIONS

BASIC PRINCIPLES

KE

Y PR

INC

IPLE

WO

RK

ING

WITH

GO

VE

RN

ME

NTS





Q amp A





30

















KE

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INC

IPLE

WO

RK

ING

WITH

GO

VERN

MEN

TS

31




FINANCIAL INTEGRITY




PRIVACY PRINCIPLES

RECORDS MANAGEMENT



KE

Y PR

INC

IPLE

PR

OTE

CTIN

G C

OM

PAN

Y A

SS

ETS







regulations


Q amp A



32












KE

Y PR

INC

IPLE

PRO

TECTING

COM

PAN

Y ASSETS

33










Q amp A



34


















KE

Y PR

INC

IPLE

PRO

TECTING

COM

PAN

Y ASSETS

35









Q amp A



36





Q amp A




KE

Y PR

INC

IPLE

PRO

TECTING

COM

PAN

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37








38


KE

Y P

RIN

CIP

LE S

UP

PO

RTI

NG

OU

R C

OM

MU

NIT

IES

















Q amp A



39







Q amp A







40













KE

Y PR

INC

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SUPPO

RTIN

G O

UR

COM

MU

NITIES

41

ADDITIONAL HELP














42











43














Q amp A



22












KE

Y PR

INC

IPLE

AVOID

ING

CO

NFLICTS

23




Q amp A





24








KE

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INC

IPLE

AVOID

ING

CO

NFLICTS


25







KE

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INC

IPLE

CO

ND

UC

TING

BU

SIN

ES

S









ndash Manipulation

ndash Concealment




Q amp A



26








KE

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INC

IPLE

CON

DU

CTING

BU

SINESS

27












28





Q amp A





KE

Y PR

INC

IPLE

CON

DU

CTING

BU

SINESS

29




YOUR OBLIGATIONS

BASIC PRINCIPLES

KE

Y PR

INC

IPLE

WO

RK

ING

WITH

GO

VE

RN

ME

NTS





Q amp A





30

















KE

Y PR

INC

IPLE

WO

RK

ING

WITH

GO

VERN

MEN

TS

31




FINANCIAL INTEGRITY




PRIVACY PRINCIPLES

RECORDS MANAGEMENT



KE

Y PR

INC

IPLE

PR

OTE

CTIN

G C

OM

PAN

Y A

SS

ETS







regulations


Q amp A



32












KE

Y PR

INC

IPLE

PRO

TECTING

COM

PAN

Y ASSETS

33










Q amp A



34


















KE

Y PR

INC

IPLE

PRO

TECTING

COM

PAN

Y ASSETS

35









Q amp A



36





Q amp A




KE

Y PR

INC

IPLE

PRO

TECTING

COM

PAN

Y ASSETS

37








38


KE

Y P

RIN

CIP

LE S

UP

PO

RTI

NG

OU

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OM

MU

NIT

IES

















Q amp A



39







Q amp A







40













KE

Y PR

INC

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SUPPO

RTIN

G O

UR

COM

MU

NITIES

41

ADDITIONAL HELP














42











43













KE

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INC

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AVOID

ING

CO

NFLICTS

23




Q amp A





24








KE

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INC

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AVOID

ING

CO

NFLICTS


25







KE

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INC

IPLE

CO

ND

UC

TING

BU

SIN

ES

S









ndash Manipulation

ndash Concealment




Q amp A



26








KE

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INC

IPLE

CON

DU

CTING

BU

SINESS

27












28





Q amp A





KE

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INC

IPLE

CON

DU

CTING

BU

SINESS

29




YOUR OBLIGATIONS

BASIC PRINCIPLES

KE

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INC

IPLE

WO

RK

ING

WITH

GO

VE

RN

ME

NTS





Q amp A





30

















KE

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INC

IPLE

WO

RK

ING

WITH

GO

VERN

MEN

TS

31




FINANCIAL INTEGRITY




PRIVACY PRINCIPLES

RECORDS MANAGEMENT



KE

Y PR

INC

IPLE

PR

OTE

CTIN

G C

OM

PAN

Y A

SS

ETS







regulations


Q amp A



32












KE

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INC

IPLE

PRO

TECTING

COM

PAN

Y ASSETS

33










Q amp A



34


















KE

Y PR

INC

IPLE

PRO

TECTING

COM

PAN

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35









Q amp A



36





Q amp A




KE

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INC

IPLE

PRO

TECTING

COM

PAN

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37








38


KE

Y P

RIN

CIP

LE S

UP

PO

RTI

NG

OU

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OM

MU

NIT

IES

















Q amp A



39







Q amp A







40













KE

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INC

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SUPPO

RTIN

G O

UR

COM

MU

NITIES

41

ADDITIONAL HELP














42











43





Q amp A





24








KE

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INC

IPLE

AVOID

ING

CO

NFLICTS


25







KE

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INC

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CO

ND

UC

TING

BU

SIN

ES

S









ndash Manipulation

ndash Concealment




Q amp A



26








KE

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INC

IPLE

CON

DU

CTING

BU

SINESS

27












28





Q amp A





KE

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INC

IPLE

CON

DU

CTING

BU

SINESS

29




YOUR OBLIGATIONS

BASIC PRINCIPLES

KE

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INC

IPLE

WO

RK

ING

WITH

GO

VE

RN

ME

NTS





Q amp A





30

















KE

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INC

IPLE

WO

RK

ING

WITH

GO

VERN

MEN

TS

31




FINANCIAL INTEGRITY




PRIVACY PRINCIPLES

RECORDS MANAGEMENT



KE

Y PR

INC

IPLE

PR

OTE

CTIN

G C

OM

PAN

Y A

SS

ETS







regulations


Q amp A



32












KE

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INC

IPLE

PRO

TECTING

COM

PAN

Y ASSETS

33










Q amp A



34


















KE

Y PR

INC

IPLE

PRO

TECTING

COM

PAN

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35









Q amp A



36





Q amp A




KE

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INC

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PRO

TECTING

COM

PAN

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37








38


KE

Y P

RIN

CIP

LE S

UP

PO

RTI

NG

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OM

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NIT

IES

















Q amp A



39







Q amp A







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KE

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INC

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SUPPO

RTIN

G O

UR

COM

MU

NITIES

41

ADDITIONAL HELP














42











43









KE

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INC

IPLE

AVOID

ING

CO

NFLICTS


25







KE

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INC

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CO

ND

UC

TING

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SIN

ES

S









ndash Manipulation

ndash Concealment




Q amp A



26








KE

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INC

IPLE

CON

DU

CTING

BU

SINESS

27












28





Q amp A





KE

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INC

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CON

DU

CTING

BU

SINESS

29




YOUR OBLIGATIONS

BASIC PRINCIPLES

KE

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INC

IPLE

WO

RK

ING

WITH

GO

VE

RN

ME

NTS





Q amp A





30

















KE

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INC

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WO

RK

ING

WITH

GO

VERN

MEN

TS

31




FINANCIAL INTEGRITY




PRIVACY PRINCIPLES

RECORDS MANAGEMENT



KE

Y PR

INC

IPLE

PR

OTE

CTIN

G C

OM

PAN

Y A

SS

ETS







regulations


Q amp A



32












KE

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INC

IPLE

PRO

TECTING

COM

PAN

Y ASSETS

33










Q amp A



34


















KE

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INC

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PRO

TECTING

COM

PAN

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35









Q amp A



36





Q amp A




KE

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INC

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PRO

TECTING

COM

PAN

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37








38


KE

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RIN

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LE S

UP

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RTI

NG

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OM

MU

NIT

IES

















Q amp A



39







Q amp A







40













KE

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INC

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SUPPO

RTIN

G O

UR

COM

MU

NITIES

41

ADDITIONAL HELP














42











43








KE

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INC

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CO

ND

UC

TING

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SIN

ES

S









ndash Manipulation

ndash Concealment




Q amp A



26








KE

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INC

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CON

DU

CTING

BU

SINESS

27












28





Q amp A





KE

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INC

IPLE

CON

DU

CTING

BU

SINESS

29




YOUR OBLIGATIONS

BASIC PRINCIPLES

KE

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INC

IPLE

WO

RK

ING

WITH

GO

VE

RN

ME

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Q amp A





30

















KE

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INC

IPLE

WO

RK

ING

WITH

GO

VERN

MEN

TS

31




FINANCIAL INTEGRITY




PRIVACY PRINCIPLES

RECORDS MANAGEMENT



KE

Y PR

INC

IPLE

PR

OTE

CTIN

G C

OM

PAN

Y A

SS

ETS







regulations


Q amp A



32












KE

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INC

IPLE

PRO

TECTING

COM

PAN

Y ASSETS

33










Q amp A



34


















KE

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INC

IPLE

PRO

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COM

PAN

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35









Q amp A



36





Q amp A




KE

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INC

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PRO

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COM

PAN

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37








38


KE

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RIN

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LE S

UP

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OM

MU

NIT

IES

















Q amp A



39







Q amp A







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KE

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INC

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RTIN

G O

UR

COM

MU

NITIES

41

ADDITIONAL HELP














42











43






KE

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INC

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CO

ND

UC

TING

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SIN

ES

S









ndash Manipulation

ndash Concealment




Q amp A



26








KE

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INC

IPLE

CON

DU

CTING

BU

SINESS

27












28





Q amp A





KE

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INC

IPLE

CON

DU

CTING

BU

SINESS

29




YOUR OBLIGATIONS

BASIC PRINCIPLES

KE

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INC

IPLE

WO

RK

ING

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GO

VE

RN

ME

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Q amp A





30

















KE

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INC

IPLE

WO

RK

ING

WITH

GO

VERN

MEN

TS

31




FINANCIAL INTEGRITY




PRIVACY PRINCIPLES

RECORDS MANAGEMENT



KE

Y PR

INC

IPLE

PR

OTE

CTIN

G C

OM

PAN

Y A

SS

ETS







regulations


Q amp A



32












KE

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INC

IPLE

PRO

TECTING

COM

PAN

Y ASSETS

33










Q amp A



34


















KE

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INC

IPLE

PRO

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COM

PAN

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35









Q amp A



36





Q amp A




KE

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INC

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PRO

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COM

PAN

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37








38


KE

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RIN

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LE S

UP

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OM

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NIT

IES

















Q amp A



39







Q amp A







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KE

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INC

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SUPPO

RTIN

G O

UR

COM

MU

NITIES

41

ADDITIONAL HELP














42











43










ndash Manipulation

ndash Concealment




Q amp A



26








KE

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INC

IPLE

CON

DU

CTING

BU

SINESS

27












28





Q amp A





KE

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INC

IPLE

CON

DU

CTING

BU

SINESS

29




YOUR OBLIGATIONS

BASIC PRINCIPLES

KE

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INC

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WO

RK

ING

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GO

VE

RN

ME

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Q amp A





30

















KE

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INC

IPLE

WO

RK

ING

WITH

GO

VERN

MEN

TS

31




FINANCIAL INTEGRITY




PRIVACY PRINCIPLES

RECORDS MANAGEMENT



KE

Y PR

INC

IPLE

PR

OTE

CTIN

G C

OM

PAN

Y A

SS

ETS







regulations


Q amp A



32












KE

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INC

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PRO

TECTING

COM

PAN

Y ASSETS

33










Q amp A



34


















KE

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INC

IPLE

PRO

TECTING

COM

PAN

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35









Q amp A



36





Q amp A




KE

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INC

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PRO

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COM

PAN

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37








38


KE

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RIN

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LE S

UP

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OM

MU

NIT

IES

















Q amp A



39







Q amp A







40













KE

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INC

IPLE

SUPPO

RTIN

G O

UR

COM

MU

NITIES

41

ADDITIONAL HELP














42











43









KE

Y PR

INC

IPLE

CON

DU

CTING

BU

SINESS

27












28





Q amp A





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CON

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29




YOUR OBLIGATIONS

BASIC PRINCIPLES

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Q amp A





30

















KE

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31




FINANCIAL INTEGRITY




PRIVACY PRINCIPLES

RECORDS MANAGEMENT



KE

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INC

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PR

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PAN

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Q amp A



32












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INC

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33










Q amp A



34


















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INC

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35









Q amp A



36





Q amp A




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37








38


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Q amp A



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Q amp A







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ADDITIONAL HELP














42











43













28





Q amp A





KE

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CON

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BU

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29




YOUR OBLIGATIONS

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KE

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INC

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Q amp A





30

















KE

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31




FINANCIAL INTEGRITY




PRIVACY PRINCIPLES

RECORDS MANAGEMENT



KE

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INC

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PR

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G C

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PAN

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Q amp A



32












KE

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INC

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COM

PAN

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33










Q amp A



34


















KE

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INC

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PRO

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COM

PAN

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35









Q amp A



36





Q amp A




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INC

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37








38


KE

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Q amp A



39







Q amp A







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KE

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41

ADDITIONAL HELP














42











43






Q amp A





KE

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CON

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BU

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29




YOUR OBLIGATIONS

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KE

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Q amp A





30

















KE

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INC

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WO

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ING

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MEN

TS

31




FINANCIAL INTEGRITY




PRIVACY PRINCIPLES

RECORDS MANAGEMENT



KE

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INC

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PR

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G C

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PAN

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ETS







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Q amp A



32












KE

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INC

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COM

PAN

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33










Q amp A



34


















KE

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INC

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PAN

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35









Q amp A



36





Q amp A




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37








38


KE

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Q amp A



39







Q amp A







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KE

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41

ADDITIONAL HELP














42











43





YOUR OBLIGATIONS

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KE

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Q amp A





30

















KE

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31




FINANCIAL INTEGRITY




PRIVACY PRINCIPLES

RECORDS MANAGEMENT



KE

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INC

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PR

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G C

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PAN

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Q amp A



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33










Q amp A



34


















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INC

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COM

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35









Q amp A



36





Q amp A




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37








38


KE

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Q amp A



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Q amp A







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KE

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41

ADDITIONAL HELP














42











43



YOUR OBLIGATIONS

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KE

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Q amp A





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KE

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31




FINANCIAL INTEGRITY




PRIVACY PRINCIPLES

RECORDS MANAGEMENT



KE

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INC

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PR

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G C

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PAN

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Q amp A



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INC

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33










Q amp A



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35









Q amp A



36





Q amp A




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37








38


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Q amp A



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41

ADDITIONAL HELP














42











43






Q amp A





30

















KE

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WO

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31




FINANCIAL INTEGRITY




PRIVACY PRINCIPLES

RECORDS MANAGEMENT



KE

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INC

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PR

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G C

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PAN

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ETS







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Q amp A



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33










Q amp A



34


















KE

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35









Q amp A



36





Q amp A




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37








38


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Q amp A



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ADDITIONAL HELP














42











43


















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31




FINANCIAL INTEGRITY




PRIVACY PRINCIPLES

RECORDS MANAGEMENT



KE

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INC

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PAN

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Q amp A



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Q amp A



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Q amp A



36





Q amp A




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37








38


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ADDITIONAL HELP














42











43





FINANCIAL INTEGRITY




PRIVACY PRINCIPLES

RECORDS MANAGEMENT



KE

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INC

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PAN

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Q amp A



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Q amp A



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Q amp A



36





Q amp A




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37








38


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ADDITIONAL HELP














42











43



FINANCIAL INTEGRITY




PRIVACY PRINCIPLES

RECORDS MANAGEMENT



KE

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INC

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Q amp A



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Q amp A



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Q amp A



36





Q amp A




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37








38


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42











43








regulations


Q amp A



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Q amp A



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Q amp A



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Q amp A




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38


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ADDITIONAL HELP














42











43













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Q amp A



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38


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ADDITIONAL HELP














42











43











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38


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ADDITIONAL HELP














42











43



















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Q amp A



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38


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KE

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ADDITIONAL HELP














42











43










Q amp A



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Q amp A




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38


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41

ADDITIONAL HELP














42











43






Q amp A




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37








38


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41

ADDITIONAL HELP














42











43









38


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41

ADDITIONAL HELP














42











43



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Q amp A



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KE

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41

ADDITIONAL HELP














42











43


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Q amp A



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KE

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INC

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41

ADDITIONAL HELP














42











43













Q amp A



39







Q amp A







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KE

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INC

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SUPPO

RTIN

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MU

NITIES

41

ADDITIONAL HELP














42











43








Q amp A







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KE

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INC

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G O

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COM

MU

NITIES

41

ADDITIONAL HELP














42











43














KE

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SUPPO

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MU

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41

ADDITIONAL HELP














42











43


ADDITIONAL HELP














42











43












43



Employee Code of Conduct - BNY Mellon … · · 2018-01-31Anti-corruption and improper payments // 28 ... Audit, Compliance, Human Resources and our Ethics Ofﬁce are readily available

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